Eversheds Sutherland Tax Reform Law Blog
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Unpacking the big beautiful international tax provisions of the One Big Beautiful Bill

Although the majority of the tax bill introduced by the House Committee on Ways and Means on May 12, 2025 is focused on the Administration’s domestic agenda, the bill includes some material changes to the international tax rules, as well as a change to the Tariff Act of 1930 (Tariff Act). The international tax changes include: A new section 899 regarding the imposition of unfair taxes...

Legal Alert: An incomplete picture: Democratic senators release “framework” for international tax overhaul

On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The legislative language is generally in line with the International Tax Overhaul proposals first released by the Senators on April 5, 2021. The draft legislation includes some provisions...