Tax Reform, Foreign Tax, Income Taxes

Is Revenge a Dish Best Served Under the Tax Code?

Cadwalader, Wickersham & Taft LLP on 6/24/2025

Among the myriad provisions of the budget bill that passed the U.S. House of Representatives last month, one that has recently gained increased prominence in recent weeks is proposed Section 899, increasingly referred to as...more

Retaliatory Taxes: Pending Legislation in U.S. Congress May Adversely Impact Returns on Inbound Investment

Davies Ward Phillips & Vineberg LLP on 6/23/2025

As the U.S. tax reform process continues, the comprehensive tax bill that passed the House of Representatives in May is now under active consideration in the Senate. Earlier this week, the Senate Finance Committee released...more

Update: Senate Finance Committee Releases Its Version of Section 899 of the One Big Beautiful Bill

Paul Hastings LLP on 6/19/2025

On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...more

How REITs are Impacted by the “One Big Beautiful Bill Act”

Sullivan & Worcester on 5/29/2025

The U.S. House of Representatives, by a one-vote margin, passed the “One Big Beautiful Bill Act” (the “House Bill”) early in the morning on May 22, 2025. The House Bill has yet to be considered by the U.S. Senate and will...more

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on 12/13/2018

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

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 7/23/2018

• 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