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The One Big Beautiful Bill Act makes three major changes to the interest deduction limitation provision of §163(j). Pub. L. No. 119-21, §70303, §70341 (July 4, 2025), applicable to taxable years beginning after December 31, 2024. This article reviews the three changes and then focuses on the new rule for capitalized interest.

On July 4, 2025, the One Big, Beautiful Bill Act was signed into law, making important changes to the Internal Revenue Code. The Act has implications for US and non-US companies and their domestic and international transactions, capital investment, and research and development activities, amongst other areas, which carry significant weight for the cryptocurrency/digital asset industry. From cryptocurrency exchanges, payment processors, asset managers and cryptocurrency funds to mining companies, token issuers, custodians, and centralized or decentralized lending platforms, the Act’s provisions reshape the tax landscape in ways that demand close attention.

China has introduced a new tax reporting regime requiring internet platforms—both domestic and overseas—to regularly report tax-related information to Chinese authorities. This move, under State Council Decree No. 810 and STA Bulletin [2025] No. 15, aims to close tax loopholes and enforce compliance. Platforms must now implement robust systems to meet these obligations, with significant implications for data privacy and cross-border data transfers.

A new Strategic Goods (Control) Order 2015 (“SGCO 2015”) will replace the current SGCO 2013 with effect from 2 November 2015. According to Singapore Customs, the SGCO 2015 brings Singapore’s strategic goods control list up to date with the 2014 Wassenaar Arrangement Munitions List and the 2014 European Union’s List of Dual-Use Items.