News & Analysis as of

Internal Revenue Code (IRC) Proposed Legislation

Herbert Smith Freehills Kramer

Proposed IRC section 899 ‘revenge tax’ targets residents of certain discriminatory/offending foreign countries

On June 16, 2025, the Senate Finance Committee released its proposed version of the “One Big Beautiful Bill Act” (the Senate Bill). The House of Representatives passed its version of the bill on May 22, 2025 (the House...more

DLA Piper

Senate Tax Bill: Key Points for the Investment Funds Industry

DLA Piper on

The US Senate released a draft tax bill (Senate Tax Bill) on June 16, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management community, with a focus on how the Senate Tax Bill...more

Mayer Brown

US Senate Finance Committee Makes Changes to Proposed Section 899

Mayer Brown on

The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier...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

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

Paul Hastings LLP on

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

Alston & Bird

House Reconciliation Bill Expands and Improves Health Savings Accounts and Individual Coverage Health Reimbursement Arrangements

Alston & Bird on

The House-passed reconciliation bill would significantly modify health savings accounts (HSAs) and individual coverage health reimbursement arrangements (ICHRAs). Our Employee Benefits & Executive Compensation Group unpacks...more

Troutman Pepper Locke

Tax Credit Implications of the One Big Beautiful Bill Act

Troutman Pepper Locke on

On May 22, the U.S. House of Representatives passed an amended version of H.R. 1—the One Big Beautiful Bill Act (the Bill) — by a vote of 215-214. The House-passed version of the bill, slated to be considered by the Senate...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

Troutman Pepper Locke on

On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...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

Proskauer - Tax Talks

Proposed Changes to Interest Rate Tax Treatment for RICs

Proskauer - Tax Talks on

The One Big Beautiful Bill Act (the “OBBBA“), passed by the U.S. House of Representatives (the “House“) on May 22, 2025, is a comprehensive legislative package that seeks to implement sweeping reforms in tax policy,...more

DLA Piper

REIT Tax News - June 2025

DLA Piper on

On May 22, 2025, the House of Representatives passed a tax bill (House Tax Bill) that proposes to make permanent – and increase – the section 199A deduction for ordinary REIT dividends to 23 percent. This change would reduce...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for the Real Estate Industry

Troutman Pepper Locke on

On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Investment Funds and Sponsors

Troutman Pepper Locke on

On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more

Cooley LLP

Proposed Tax Legislation Would Permit Immediate Deduction of Domestic R&E Expenditures for Limited Period

Cooley LLP on

On May 22, 2025, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA), which includes a temporary suspension of the amortization requirement for domestic research and experimentation (R&E)...more

Cooley LLP

Proposed Federal Tax Legislation Would Effect Three Key Changes to State and Local Tax Deductibility Limits

Cooley LLP on

On May 22, the House of Representatives passed proposed tax legislation titled, “The One, Big, Beautiful Bill” (TOBBB), which will now be debated in the Senate. Among other proposals, if enacted into law, TOBBB would make...more

Proskauer - Tax Talks

Senator Tillis Introduced a Bill Taxing Proceeds of Litigation Financing Agreements

Proskauer - Tax Talks on

Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more

Venable LLP

New ERC Cutoff in “One Big Beautiful Bill” Runs into Serious Parliamentary and Constitutional Headwinds

Venable LLP on

The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more

ArentFox Schiff

House Advances Tax Legislation: Implications for Tax-Exempt Organizations

ArentFox Schiff on

Last week, the US House of Representatives passed H.R. 1, the “One Big Beautiful Bill Act.” This alert highlights the provisions in the Bill that could impact tax-exempt organizations....more

A&O Shearman

Summary of key provisions in House reconciliation bill

A&O Shearman on

On May 22, 2025, the U.S. House of Representatives narrowly passed the House budget reconciliation bill (H.R. 1) (the “House Bill”) by a party-line vote of 215 – 214. The House Bill, which includes significant tax law...more

Hogan Lovells

Full U.S. House passes “One Big Beautiful Bill” – Impact on energy

Hogan Lovells on

On May 22, 2025 the House of Representatives, by a vote of 215-214 (no Democrats supporting), passed the One Big, Beautiful Bill Act (“OBBB”) which includes manager’s amendment changes from the version passed by the Ways and...more

Pillsbury - SeeSalt Blog

California Legislature Advances Broad Federal Tax Conformity Bill (SB 711)

Senate Bill 711 (S.B. 711) would update California’s conformity date to the Internal Revenue Code (IRC) from January 1, 2015, to January 1, 2025. If enacted, this change would apply to taxable years beginning on or after...more

Pillsbury Winthrop Shaw Pittman LLP

The Proposed “Big, Beautiful Bill” May Disrupt Sports Team Investment Strategy

The recently proposed “Big, Beautiful Bill” (BBB), currently under preliminary markup in the Senate Finance Committee, includes a suite of tax provisions aimed at deficit reduction, corporate reform and base-broadening. Of...more

Eversheds Sutherland (US) LLP

The One Big Beautiful Bill – sports industry sweats the over/under

As the “One Big Beautiful Bill” continues its legislative path through Congress, it remains too close to call on how the final legislation will impact the sports industry. On May 22, 2025, the House of Representatives...more

DLA Piper

House Passes Sweeping Tax Bill: Top Points for the Investment Funds Industry

DLA Piper on

On May 22, 2025, the House of Representatives passed a tax bill with some limited amendments (House Tax Bill). The House Tax Bill will now head to the Senate, where additional amendments could be made. Below, we outline five...more

Frost Brown Todd

Three Tax Issues Manufacturers Should Watch in 2025 Budget Bill

Frost Brown Todd on

On May 13, the House Ways and Means Committee voted to approve a $3.8 trillion tax bill that would make permanent much of the 2017 Tax Cuts and Jobs Act. The bill then moved to the House Budget Committee, where it was merged...more

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