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Foreign Entities GILTI tax

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

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

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