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ASKramer Law

Business Taxation of Hedging Transactions Part V: Consolidated Groups

ASKramer Law on

Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more

Rivkin Radler LLP

“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*

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Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more

International Lawyers Network

Establishing a Business Entity in Germany (Updated)

Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

Allen Barron, Inc. on

Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

Nutter McClennen & Fish LLP

Estate and Income Tax Provisions in Pending Massachusetts Tax Relief Package

The Massachusetts House and Senate voted in favor of a Massachusetts tax relief bill. The legislation is now on Governor Maura Healey’s desk, and she has until October 8th to act. More than two decades have passed since the...more

Proskauer - Tax Talks

Proskauer Tax Talks: Green Book 2024

Proskauer - Tax Talks on

On March 9, 2023, the Biden Administration released the Fiscal Year 2024 Budget, and the “General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals,” which is commonly referred to as the “Green Book.”...more

Proskauer Rose LLP

UK Tax Round Up - March 2023 - 2

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Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

International Lawyers Network

Buying and Selling Real Estate in the Netherlands (Updated)

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER DUTCH LAW - Introduction - The purchase of an immovable property is a mutual agreement. Neither the seller nor the buyer has the obligation to make use of the services of...more

International Lawyers Network

Establishing A Business Entity In India (Updated)

1. Types of Business Entities - 1.1 Description of the types of entities available in India through which to conduct business: A foreign entity may establish a business presence in India by: • opening a liaison...more

International Lawyers Network

Establishing a Business Entity in Germany (Updated)

Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more

Morgan Lewis

Planning for the Massachusetts ‘Millionaires Tax’

Morgan Lewis on

The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more

Poyner Spruill LLP

Planning to Exclude Gain on Sale of Corporate Stock

Poyner Spruill LLP on

When incorporating a business, you may form a C corporation or S corporation.  If you choose a C corporation, consideration should be given to qualifying the stock as “qualified small business stock” (“QSBS”)....more

Burr & Forman

Changes in Tax Rates for 2023

Burr & Forman on

The IRS has issued Revenue Procedure 2022-38, which sets forth inflation-adjusted items for various provisions of the Internal Revenue Code which will be applicable in 2023. Here are some of the highlights...more

Dechert LLP

Another Stab at Carried Interests Under the Inflation Reduction Act of 2022

Dechert LLP on

On July 27, 2022, Senator Joe Manchin III (D-W.Va.) and Majority Leader Charles E. Schumer (D-N.Y.) introduced legislation entitled the “Inflation Reduction Act of 2022” (the “Reconciliation Bill”). The Reconciliation Bill is...more

Cadwalader, Wickersham & Taft LLP

A Pocket Guide to the 2023 Budget Proposals

On March 28, 2022, the Biden Administration released its budget proposal for Fiscal Year 2023 (the Budget). We summarize below the tax aspects of the Budget of particular interests to U.S. corporate taxpayers, financial...more

Freeman Law

Effectively Connected Income

Freeman Law on

Effectively Connected Income - Unlike FDAP income, the United States taxes effectively connected income (“ECI”) on a net basis. Effectively connected income is income that is effectively connected with the conduct of a U.S....more

Keating Muething & Klekamp PLL

Two New Private Letter Rulings Inform Code Section 1202's Qualified Trade or Business Analysis

Section 1202 of the Internal Revenue Code provides savvy business founders and investors an opportunity for large tax savings. In fact, if the entity and the business exit are structured correctly, upon an exit, the founders...more

International Lawyers Network

Buying and Selling Real Estate in the Netherlands (Updated)

KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER DUTCH LAW - Introduction - The purchase of an immovable property is a mutual agreement. Neither the seller nor the buyer has the obligation to make use of the services of...more

International Lawyers Network

Establishing a Business Entity in Germany (Updated)

Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more

International Lawyers Network

Establishing A Business Entity In Austria (Updated)

1. Introduction - In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability...more

International Lawyers Network

Establishing a Business Entity in Argentina (Updated)

Types of business entities - The two most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”) and the corporation (“Sociedad Anónima” or...more

Rivkin Radler LLP

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

Rivkin Radler LLP on

Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

Rivkin Radler LLP

The 2022 Federal Budget, Including Tax Changes – Are We There Yet?

Rivkin Radler LLP on

It Seemed Like a Good Idea- In July of this year, one of my partners, who chairs the board of a local grantmaking public charity, asked if I would present at a CLE program to be sponsored by the charity on October 28 (last...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Freeman Law

Estimating Tax Deductions: The Cohan Rule

Freeman Law on

The Cohan Rule: Tax Deductions with Incomplete Records - The “Cohan rule” is derived from the Second Circuit’s 1930 decision, Cohan v. Commissioner, which allowed the taxpayer to approximate travel and entertainment...more

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