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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

McDermott Will & Schulte

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

McDermott Will & Schulte 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

Hogan Lovells

New IRS proposed regulations under Section 956 substantially reduce "deemed dividend" concerns with respect to pledges and...

Hogan Lovells on

Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations thereunder, deemed dividends were potentially created when a U.S. borrower...more

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