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Tax Reform Foreign Tax Credits

Cozen O'Connor

What Canadian High Net Worth Families Should Know About the U.S. One Big Beautiful Bill

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The United States recently passed tax legislation called the One Big Beautiful Bill Act (OBBBA), a follow-up to the 2017 Trump tax cuts. While the bill is American, many Canadian families with cross-border ties, including...more

Herbert Smith Freehills Kramer

Tax Provisions in the One Big Beautiful Bill Act

On July 4, President Trump signed into law the One Big Beautiful Bill Act (the Act). While the Act covers a wide swath of territory, the core of the Act is its tax provisions. The Act (i) makes permanent many of the tax...more

Cadwalader, Wickersham & Taft LLP

Business Tax Highlights from the 2025 Tax Act

On July 4, 2025, President Trump signed into law the FY 2025 budget bill (the “Act”), which includes substantial business tax proposals.  At a high level, the Act permanently extends many of the 2017 Tax Cuts and Jobs Act’s...more

Holland & Knight LLP

A Look at the International Tax Changes in the One Big Beautiful Bill Act

Holland & Knight LLP on

The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more

McDermott Will & Schulte

Corporate taxpayers: Key One Big Beautiful Bill Act changes to international and domestic taxes

On July 4, 2025, US President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law. The legislation introduces significant changes to both international and domestic business tax rules for US taxpayers. While...more

WilmerHale

International Tax Provisions of the One Big Beautiful Bill Act (OBBBA)

WilmerHale on

On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBBA), marking a significant overhaul of the international tax landscape. This legislation introduces several key changes aimed at refining...more

Bilzin Sumberg

Key International Tax Changes From the One Big Beautiful Bill Act

Bilzin Sumberg on

On July 4th, 2025, President Trump signed into law the One Big Beautiful Bill Act (“OBBBA”). This alert expands upon our Firm’s prior alert and is intended to summarize the main tax law changes that may impact: (i) U.S....more

Ropes & Gray LLP

2025 Tax Legislation Update: One Big Beautiful Bill Act Narrowly Passes Senate

Ropes & Gray LLP on

The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...more

DLA Piper

US Tax and Trade Policy Developments: Potential Implications for Foreign Tax Credits, the State of the Budget Resolution, and...

DLA Piper on

Last week, President Donald Trump issued two Executive Orders (EOs) that address digital services taxes enacted by international trading partners and income taxes paid by US taxpayers to the People’s Republic of China (PRC),...more

McDermott Will & Schulte

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

McDermott Will & Schulte

Court Rules Taxpayer Can Offset Foreign Tax Credits With NIIT Liability Under Tax Treaty

McDermott Will & Schulte on

In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more

Holland & Knight LLP

The Most Interesting International Tax Proposals in Biden's FY 2023 Budget

Holland & Knight LLP on

This Holland & Knight alert discusses the intersection of President Joe Biden's proposed changes to the U.S. tax code, as announced in connection with his fiscal year (FY) 2023 budget, and work underway on the global stage...more

Proskauer - Tax Talks

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand Now

Proskauer - Tax Talks on

Yesterday, on December 19, 2021, Senator Joe Manchin (D., W.Va.) said that he opposes the Build Back Better Act, which effectively prevents its passage.  While there are no immediate prospects for the Build Back Better Act to...more

Polsinelli

The Proposed Build Back Better Act Moves Forward After the House Passes a Revised Version of the Bill

Polsinelli on

Overview - Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more

ArentFox Schiff

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

ArentFox Schiff on

The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more

Bilzin Sumberg

Responsibly Funding Our Priorities – House Yields Decisive Reconciliation Action

Bilzin Sumberg on

As you may be aware, the House Ways and Means Committee recently approved a multitrillion-dollar tax package (the “Proposal”) that has significant tax impact on both individuals and corporations. ...more

Alston & Bird

The Other Green Book: Treasury Explains Administration’s Tax Proposals

Alston & Bird on

With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the...more

Holland & Knight LLP

Biden Administration's FY 2022 Budget and International Tax Changes

Holland & Knight LLP on

A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more

ArentFox Schiff

Senate Finance Committee Provides International Taxation Framework After President Biden Unveils the American Jobs Plan

ArentFox Schiff on

The proposals in the Framework echo many of the themes set forth in the Made in America Tax Plan. Last week, President Biden outlined an infrastructure spending plan (the American Jobs Plan) and a tax reform plan (the...more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

Proskauer - Tax Talks on

On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

McDermott Will & Schulte

Weekly IRS Roundup January 13 – 17, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13 – 17, 2020. January 13, 2020: The IRS published an information letter relating to the...more

Bilzin Sumberg

Looking for a GILTI-Free Structure? Try Estonia

Bilzin Sumberg on

Estonia, the small Baltic country of just 1.3 million people situated halfway between Sweden and Russia, was named “the most advanced digital society in the world” by Wired magazine. According to recent figures, Estonian...more

Chambliss, Bahner & Stophel, P.C.

Five Important Tax Highlights from 2018

2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more

Morgan Lewis

IRS Proposed Regulations Under Internal Revenue Code Section 965

Morgan Lewis on

PROPOSED REGULATIONS TO SECTION 965 - On August 1, 2018, the Internal Revenue Service (IRS) took the first step in providing significant and detailed guidance on provisions of the Tax Cuts and Jobs Act (TCJA) with the...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

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