Tax Reform, Tax Liability, Withholding Tax

“Revenge Tax”

King & Spalding on 6/13/2025

Withholding Tax Rules Under Current Law - Current US tax law provides for a 30% withholding tax on interest paid by a US borrower to foreign lenders. However, many foreign lenders are exempt from this tax, either under the...more

The Big Beautiful Bill and the Effects on Bank Lending Into the US

Troutman Pepper Locke on 6/2/2025

Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more

Swiss Tax Law Changes: New Withholding Tax Rules

Akin Gump Strauss Hauer & Feld LLP on 10/30/2018

• Under Swiss law, Swiss employers must levy an employment withholding tax on the salary received by foreign nationals who do not hold a permanent residence permit. • Only taxpayers whose salary exceeds a certain amount...more

Tax Reform – I.R.S. Updates Withholding Tax Guidance on Sales of Partnership Interests

Proskauer - Tax Talks on 5/9/2018

On April 2, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-29 (the “Notice”), announcing the intention of the IRS and the Department of the Treasury to issue regulations regarding the withholding requirements...more

Foreign Partners Victims of Tax Reform - Tax Update, Volume 2018, Issue 1

Troutman Pepper Locke on 3/19/2018

More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more

MoFo New York Tax Insights - Volume 5, Issue 5 - May 2014

Morrison & Foerster LLP on 5/12/2014

In This Issue: - Two Combined Reporting Decisions Highlight Issues Involving “Permissive” Combined Reporting - New York State Corporate Tax Reform Legislation Enacted – What You Need to Know - Appellate Court...more