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U.S. Treasury Foreign Corporations

Paul Hastings LLP

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

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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

Seward & Kissel LLP

Should you call 911 about Section 899?

Seward & Kissel LLP on

On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more

McDermott Will & Emery

The Proposed US Tax Regime for Non-US Investors and Companies

McDermott Will & Emery on

On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Troutman Pepper Locke

Practical Implications of the Interim Final Rule for BOI Reporting Under the CTA

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As we previously discussed, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule (IFR) on March 26 that narrowed the beneficial ownership information (BOI) reporting requirements under the...more

Pillsbury Winthrop Shaw Pittman LLP

CTA Deadline Approaching for Foreign Reporting Companies

The Corporate Transparency Act (CTA) was adopted by Congress in January 2021 and became effective on January 1, 2024. Under the CTA and the initial regulations implementing it, “reporting companies” (corporations, LLCs,...more

Winstead PC

Corporate Transparency Act Update: U.S. Companies No Longer Subject to Reporting Obligations

Winstead PC on

As promised, FinCEN has adopted its interim final rule and narrowed the filing requirements for Beneficial Ownership Information (“BOI”) reporting under the Corporate Transparency Act (“CTA”). This rule exempts U.S. entities...more

ArentFox Schiff

CTA Drastically Pared Back

ArentFox Schiff on

As promised by the US Department of Treasury in early March, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule removing the requirement for US companies, their beneficial owners, and US persons to...more

Bodman

U.S. Companies and Business Owners Exempted from CTA Reporting Requirements

Bodman on

The Financial Crimes Enforcement Network (“FinCEN”) has issued an interim final rule that would exempt U.S. companies and U.S. persons from reporting their beneficial ownership information (“BOI”) as part of the Corporate...more

Bracewell LLP

FinCEN Adopts Interim Final Rule Limiting CTA Reporting Requirements to Foreign Reporting Companies

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US legal entities are no longer subject to the reporting requirements of the Corporate Transparency Act (CTA). On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of Treasury...more

Ward and Smith, P.A.

Corporate Transparency Act Shakeup: Domestic Companies off the Hook, Foreign Entities Still Reporting

Ward and Smith, P.A. on

This interim final rule, released on March 21, 2025, means that only foreign entities registered to do business in the United States will still need to meet the CTA’s reporting requirements. Originally enacted to increase...more

Ruder Ware

Bye Bye Bye: FinCEN Issues CTA Update

Ruder Ware on

On March 21, 2025, FinCEN announced an end to Corporate Transparency Act (CTA) reporting requirements for U.S. citizens and domestic companies. In line with the U.S. Department of Treasury’s announcement earlier this month,...more

Downs Rachlin Martin PLLC

Corporate Transparency Act – FinCEN Announces Domestic Reporting Companies Exempt From Filing

As promised, in order to reduce the burdens on placed on legitimate businesses, while still working to detect, prevent, and prosecute financial crimes, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN)...more

McGuireWoods LLP

Treasury Department Formally Exempts U.S. Companies from CTA

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The guidance U.S. companies have been waiting for after years of ups and downs is finally here. In line with our last update, on March 21, 2025, FinCEN issued an interim final rule exempting U.S. companies and persons from...more

Flaster Greenberg PC

Corporate Transparency Act Update - FinCEN Interim Rule

Flaster Greenberg PC on

On March 21, FinCEN issued an interim rule that implements the reduced scope of the Corporate Transparency Act (“CTA”) previously announced on March 2....more

Adams & Reese

CTA Reporting No Longer Required by U.S. Domestic Companies; Foreign Companies Only, Says FinCEN

Adams & Reese on

U.S. companies can exhale. All entities created in the U.S. – including those previously known as “domestic reporting companies” and their beneficial owners – will be exempt from Corporate Transparency Act (CTA) reporting...more

Neal, Gerber & Eisenberg LLP

FinCEN Announces US Companies and Persons Exempt from CTA Reporting

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that exempts all domestic (US) companies from reporting under the Corporate Transparency Act (CTA). Non-U.S. companies that are...more

Mitchell, Williams, Selig, Gates & Woodyard,...

FinCEN Beneficial Ownership Reporting No Longer Required for all U.S. Companies

After months of uncertainty regarding enforcement of beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA), Financial Crimes Enforcement Network (FinCEN) has issued new rules...more

Fenwick & West LLP

U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications

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The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

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As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

McDermott Will & Emery

Five Key Takeaways From the Proposed PTEP Regulations

McDermott Will & Emery on

Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more

Whiteford

Client Alert: DOJ and OFAC Actions Showcase Expansive U.S. Oversight of Foreign Conduct

Whiteford on

The U.S. Department of Justice (DOJ) and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) have recently announced two enforcement actions that demonstrate the U.S. government's aggressive and...more

McDermott Will & Emery

IRS Issues Final Rules on Intangible Property Repatriations

McDermott Will & Emery on

With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States is increasingly...more

Vinson & Elkins LLP

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

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On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Proskauer - Tax Talks

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

Proskauer - Tax Talks on

On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more

Vinson & Elkins LLP

IRS Releases Final Regulations Impacting FIRPTA Exemption for Domestically Controlled REITs

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On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more

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