On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more
6/17/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Digital Services Tax ,
FDAP ,
FIRPTA ,
Foreign Governments ,
Foreign Investment ,
Foreign Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
Private Funds ,
Proposed Legislation ,
Tax Rates ,
Taxation ,
U.S. Treasury ,
Withholding Tax
On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more
1/10/2023
/ C-Corporation ,
FIRPTA ,
Foreign Governments ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Pension Funds ,
Protecting Americans from Tax Hikes (PATH) Act ,
REIT ,
S-Corporation ,
Tax Exemptions ,
U.S. Treasury