Private Equity: Limited Partners

This alert describes the persons who would be subject to the changes contained in Code Section 899, the consequences of being subject to this proposed new Code section, and some of the impacts this provision would have on certain cross-border transactions.

The Trump administration has identified growth in the nuclear energy industry as a critical component of the President’s campaign to establish American energy dominance and meet the rapidly increasing need for power.

On 2 April 2025, President Trump announced a series of “reciprocal” tariffs on US imports from all countries.  The tariffs apply at different rates by country, starting at a baseline of 10% and reaching as high as 50%.  

Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions, including US operations of foreign multinational groups and inbound investments.