Under Section 892 of the US tax code, foreign governments and their controlled entities — a category that includes SWFs and ...

Section 892 is the bit of the US tax code that you really really care about if you’re a foreign government entity, one of their integral parts, or a controlled entity (eg, SWFs and some PPFs) seeking ...

The increasing complexity of the tax code is having real consequences on the American economy, with a new analysis projecting a price tag of more than half a billion dollars yearly borne by the ...

On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital ...