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Exclusions Internal Revenue Code (IRC)

Warner Norcross + Judd

Final Fiduciary Rule — Part 3: Amendments to PTEs 84-24, 75-1, 77-4, 80-83, 83-1 and 86-128

Warner Norcross + Judd on

On April 25, 2024, the U.S. Department of Labor (DOL) released regulations redefining who is an investment advice fiduciary under the Employee Retirement Income Security Act of 1974 (ERISA) and the Internal Revenue Code...more

DarrowEverett LLP

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

DarrowEverett LLP on

In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

Kohrman Jackson & Krantz LLP

Limited in Name but Not in Tax? U.S. Tax Court Increases Tax Liability for Limited Partners

Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more

Bilzin Sumberg

Inflation Adjustments for 2024: Key Information for International Private Client Practitioners

Bilzin Sumberg on

The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more

Woods Rogers

‘Tis the Season (For Charitable Giving)

Woods Rogers on

The year-end is approaching, but you still have time to work on your 2022 tax planning. Consider giving to your favorite charity to make this holiday season merry. Planned charitable giving provides you a way to maximize...more

McDermott Will & Emery

Weekly IRS Roundup February 22 – February 26, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 22, 2021 – February 26, 2021... February 25, 2021: The IRS issued an alert warning...more

Foster Garvey PC

The Oregon Department of Revenue Held Its CAT Call as Scheduled – The Business and Tax Community Were Represented

Foster Garvey PC on

As we reported last week, the Oregon Department of Revenue (“DOR”) scheduled a public hearing on June 23, 2020 to discuss the second set of temporary administrative rules relative to the Oregon Corporate Activity Tax (the...more

Proskauer Rose LLP

Lowered Interest Rates Due To Coronavirus Makes Intra-family Loans an Effective Estate Planning Tool

Proskauer Rose LLP on

As a result of the Federal Reserve Bank's recent stimulus and interest rate decreases in response to the coronavirus, intra-family loans can be used to transfer wealth to future generations with no gift tax consequences as...more

McDermott Will & Emery

Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base

McDermott Will & Emery on

On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base...more

Rosenberg Martin Greenberg LLP

Are Owners of Cannabusinesses Eligible for the Qualified Business Income Deduction Under Section 199A?

Section 199A of the Internal Revenue Code, introduced by the Tax Cuts and Jobs Act (“TCJA”), created an opportunity for business owners to substantially lower their income taxes. Subject to many qualifications, beginning in...more

Proskauer Rose LLP

Private Investment Fund Managers and Other Investment Advisers May Be Affected by the U.S. Department of Labor’s New Fiduciary...

Proskauer Rose LLP on

On April 6, 2016, the U.S. Department of Labor (DOL) issued its highly anticipated final rule addressing when a person is considered to be a fiduciary under the Employee Retirement Income Security Act of 1974 (ERISA) and the...more

K&L Gates LLP

New Nevada Commerce Tax Effective July 1, 2015

K&L Gates LLP on

While not purporting to give specific advice on Nevada tax law, the following is a summary of some of the general principals underlying the new tax law. A new Nevada Commerce Tax (“NCT”) was signed into law by Nevada Governor...more

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