News & Analysis as of

U.S. Treasury Tax Reform

Jackson Lewis P.C.

New Tax-favored Benefit for Employees with Children

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Among the federal tax changes made by the “One Big Beautiful Bill Act” (discussed in our prior post) is a new kind of custodial savings account for children (who’ve been issued a social security number) to which their or...more

Morgan Lewis

The Impact of the ‘One Big Beautiful Bill Act’ on Nuclear Tax Incentives

Morgan Lewis on

The One Big Beautiful Bill Act alters the landscape of nuclear energy tax incentives, with significant implications for nuclear developers, investors, and stakeholders. This LawFlash breaks down how the bill may affect...more

Husch Blackwell LLP

OBBBA Extends, Modifies Opportunity Zone Program

Husch Blackwell LLP on

One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more

Fox Rothschild LLP

IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful

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A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with a 2022 Treasury...more

Saul Ewing LLP

New Provision Provides Above-The-Line Deduction for Overtime Pay

Saul Ewing LLP on

The new tax legislation, part of the "One Big Beautiful Bill", includes a temporary tax break for overtime pay, allowing eligible workers to deduct a portion of their overtime earnings from their federal income taxes. Section...more

Rivkin Radler LLP

Taxes: An American Obsession?

Rivkin Radler LLP on

Last week the United States celebrated the 249th anniversary of its declaration of independence from Great Britain. In celebration of the occasion, President Trump signed into law the One Big Beautiful Act which, among other...more

Baker Botts L.L.P.

The "One Big Beautiful Bill Act" Substantially Alters Clean Energy Tax Landscape

Baker Botts L.L.P. on

On July 4, 2025, the legislation commonly known as the "One Big Beautiful Bill Act" (the “BBBA”) was enacted. The BBBA makes significant changes to the tax credits available under the Inflation Reduction Act of 2022 (the...more

Foley & Lardner LLP

What’s the Future for Renewable Energy Tax Credits in Congress?

Foley & Lardner LLP on

The One Big Beautiful Bill Act (OBBB) has a significant impact on the renewable energy sector, particularly with changes in the phase-out schedules for wind and solar projects under Section 45Y and 48E, as well as the nuances...more

Seyfarth Shaw LLP

7 Key Changes to the Qualified Opportunity Zone Incentive Under the One Big Beautiful Bill Act

Seyfarth Shaw LLP on

On July 4, President Trump signed into law H.R. 1, the One Big Beautiful Bill Act (OBBBA), a sweeping 870-page piece of legislation that introduces significant changes across various areas of federal policy. While full...more

Vinson & Elkins LLP

One Big Beautiful Bill Signed into Law – Impact on IRA Tax Credits

Vinson & Elkins LLP on

On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (H.R. 1 119th Congress) (“OBBB”) into law. OBBB made changes to various tax provisions – including tax rates, modification of treatment of state and...more

Procopio, Cory, Hargreaves & Savitch LLP

Elementos clave de la “One Big Beautiful Bill”

La Cámara de Representantes de los EE.UU. aprobó hoy, con una votación de 218 a favor y 214 en contra, la versión previamente autorizada por el Senado del proyecto de ley conocido como “One Big Beautiful Bill”. Se espera que...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

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 2025 #2

The Senate Republicans continue to meet internally and with stakeholders regarding the provisions of a reconciliation package (H.R. 1). Senate Majority Leader John Thune (R-SD) made it clear that the Senate will make...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 2025

House Passes Reconciliation Package, with Senate Expected to Make Changes: On May 22, the House of Representatives passed H.R. 1, “The One, Big, Beautiful Bill Act,” legislation authorized under the FY 2025 concurrent budget...more

Seyfarth Shaw LLP

A New Chapter for Opportunity Zones

Seyfarth Shaw LLP on

The Opportunity Zone program (the “OZ Incentive Program”), launched under the 2017 Tax Cuts and Jobs Act, was designed to spur economic development in distressed communities by offering tax incentives to investors. As part of...more

Hogan Lovells

Update: US retaliatory taxes to be abandoned following G7 agreement on Pillar Two

Hogan Lovells on

The United States has agreed with other G7 members to remove the section 899 protective tax measures from One Big Beautiful Bill in exchange for an agreement to exclude U.S. headed groups from major aspects of the OECD global...more

Whiteford

Client Alert: The Senate’s Other Big Beautiful Bill – Notable Changes to the House Version

Whiteford on

The House of Representatives previously passed H.R. 1-119th Congress (2025-2026), titled the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses sunsetting provisions of the Tax Cuts...more

K&L Gates LLP

Senate Updates Code Section 899

K&L Gates LLP on

On Monday, 16 June 2025, the Senate Finance Committee released its version (the Senate Proposal) of the Section 899 retaliatory tax provisions that also are included in the “One Big Beautiful Bill Act” (the Act) that was...more

DLA Piper

Litigation Funding Tax and Retaliatory Tax: Top Points from the Latest JCT Scores

DLA Piper on

The Joint Committee on Taxation (JCT) on June 22, 2025, released tables providing revenue estimates for provisions of the recent Senate Committee on Finance bill language (JCX-29-25) as well as those of the comparable House...more

Cadwalader, Wickersham & Taft LLP

Is Revenge a Dish Best Served Under the Tax Code?

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

Cozen O'Connor

Cozen Currents: Are Trump and MAGA One in The Same?

Cozen O'Connor on

“Famously the author of “The Art of the Deal,” President Donald Trump considers himself more of a dealmaker than an ideologue. He sees the world as zero sum and aims to gain maximum leverage. As a result, he’s not as wedded...more

Pillsbury Winthrop Shaw Pittman LLP

Status Update: Renewable Energy Tax Credits Under the Big Beautiful Bill

Most tax credits would be subject to early termination dates and phase-outs. The House bill would end the ability to sell tax credits for cash, but the Senate Finance Committee proposal would restore transferability. New...more

Davies Ward Phillips & Vineberg LLP

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

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

Paul Hastings LLP

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

Paul Hastings LLP on

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

Venable LLP

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

Venable LLP on

As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more

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