News & Analysis as of

Income Taxes

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

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You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Troutman Pepper

FERC Chief Accountant Proposes to Modify Transferability of Income Tax Credits

Troutman Pepper on

On September 12, 2024, FERC’s Chief Accountant issued a notice of proposed accounting release (“NOPAR”) to modify the transferability of income tax credits (“ITCs”) related to certain energy projects under the Inflation...more

Holland & Knight LLP

Proyecto de reforma tributaria de Colombia 2024: Lo destacable y lo cuestionable

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El Gobierno Nacional de Colombia radicó, estratégicamente, el proyecto de Ley de Financiamiento 2024, el 10 de septiembre de 2024, buscando con ello justificar el Presupuesto General de la Nación 2025 por $523 billones,...more

Pillsbury - Propel

Equity Compensation: Navigating 409A Valuations

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Private company clients frequently ask us about granting compensatory stock options to their founders, employees and other service providers, including board members, consultants and advisors. Options and other equity awards...more

Walkers

Bermuda Corporate Income Tax Considerations for Captive Insurers

Walkers on

The operating provisions of the corporate income tax regime for Bermuda legislation will be effective for fiscal years beginning on or after 1 January 2025. This will apply to "Bermuda Constituent Entities" of an "In Scope...more

Proskauer - Tax Talks

California Franchise Tax Board (FTB) to Apply Market-Based Sourcing Rules to Nonresident Directors of California Based...

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On Monday, September 9, 2024, the California FTB approved proposed amendments to California’s personal income tax code. This proposed rule would impose California income tax on non-resident/non-employee corporate...more

Obermayer Rebmann Maxwell & Hippel LLP

The Impact of a Divorce on Taxes

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The post-Labor Day surge in family law cases comes with many questions, including concerns about upcoming holidays, and whether a divorce will be finalized by year-end. For some, the imminent tax extension deadline for...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman David Schweikert, R-AZ

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy and political debates in Congress. In this episode of “The Cloakroom with...more

Eversheds Sutherland (US) LLP

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

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Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

McDermott Will & Emery

Weekly IRS Roundup August 26 – August 30, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26, 2024 – August 30, 2024. ...more

Baker Donelson

Business Income and Sales/Use Taxes: What Constitutes a Manufacturer for Certain Tax Incentives

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Manufacturing, as often noted, is the backbone of the American economy. Manufacturers not only innovate and create products that contribute to the betterment of our way of life but are also critically fundamental to our...more

Foodman CPAs & Advisors

Taxpayers Abroad are Underserved and Challenged

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The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – August 23, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19, 2024 – August 23, 2024. August 19, 2024: The IRS released Internal Revenue Bulletin...more

Cadwalader, Wickersham & Taft LLP

Liberty Global Appeals Economic Substance Doctrine Ruling

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In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more

Fisher Phillips

How Will the Election and Recent Legislative Trends Impact Tipped Wages? 4 Developments for Hospitality Employers to Watch

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There’s been a lot of buzz about tipped wages as Election Day approaches – and hospitality employers will want to track key proposals that may have a huge impact on pay practices. Former President Trump and Vice President...more

Cadwalader, Wickersham & Taft LLP

Give Unto Caesar – Crypto?

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On June 25, 2024, Congressman Matt Gaetz (R-FL) introduced H.R. 8822 (the “Bill”), which would add Section 6316A to the Code, allowing individuals to pay their federal income tax using Bitcoin. According to Gaetz, “enabling...more

Fleurinord Law PLLC

The Pros and Cons of Parents Claiming College Students as Dependents

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As the back-to-school season kicks off and college students begin their fall semester, now is the perfect time to consider the financial implications of your child heading off to college. The decision of whether to claim them...more

Cadwalader, Wickersham & Taft LLP

GE Financial Investments: What Determines Residency?

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Background - In GE Financial Investments Limited the Court of Appeal (“CoA”) overturned the Upper Tribunal’s (“UT”) decision and held that double taxation relief was not available under the UK-US double tax treaty (the...more

Lowenstein Sandler LLP

Puttin’ on Your Top Hat: How to Effectively Structure a Deferred Compensation Plan as a “Top Hat” Plan

Lowenstein Sandler LLP on

“Top hat plans” —non-qualified deferred compensation plans that can be exempt from most of the requirements of Employee Retirement Income Security Act of 1974 or ERISA—can be a useful tool for employers looking to provide...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Purchasing U.S. Real Estate by Non-U.S. Persons

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Non-Americans who wish to purchase U.S. real estate should be aware of the tax consequences of owning real estate here. George McCormick discusses these tax issues and steps to minimize their impact....more

Foley & Lardner LLP

Unlocking the Power of Equity-Based Incentive Compensation: An Overview of Incentive Stock Options (ISOs)

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This article is the third in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees?...more

Lippes Mathias LLP

Surrendering U.S. Citizenship: How it Can Help, How it Can Hurt

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U.S. citizenship is a privilege for many, but it can also be a burdensome and unwanted obligation for others. Some individuals find themselves to be U.S. citizens without wanting to be, such as if their parents...more

Miller Canfield

Why Shouldn’t Equitable Tolling Apply to the Federal Tax Refund Look-Back Period?

Miller Canfield on

In Libitzky v. United States, the United States Court of Appeals for the Ninth Circuit affirmed disallowance of a $700,000 federal income tax refund claim. The court said that this was an “unfortunate” case, but they were...more

Baker Botts L.L.P.

Form SD Deadline Approaching for Resource Extraction Issuers: Reminder and FAQs

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As previously discussed in our Client Alert issued on December 18, 2020 (available here), the U.S. Securities and Exchange Commission (the “Commission”) adopted its final rule (the “Final Rule,” available here) requiring...more

McDermott Will & Emery

Family Office Symposium 2024 | Key Takeaways

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McDermott’s Family Office Symposium 2024 gathered more than 275 family office executives to explore creative solutions to navigate complexity and gain fresh perspectives on the challenges they face. Over two days,...more

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