News & Analysis as of

Income Taxes › Tax Liability

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 -
Foodman CPAs & Advisors

Taxpayers Abroad are Underserved and Challenged

Foodman CPAs & Advisors on

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

Cadwalader, Wickersham & Taft LLP

Liberty Global Appeals Economic Substance Doctrine Ruling

Cadwalader, Wickersham & Taft LLP on

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

Cadwalader, Wickersham & Taft LLP

Give Unto Caesar – Crypto?

Cadwalader, Wickersham & Taft LLP on

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

Gray Reed

Breaking Up Is Not Always Hard To Do—Consider A Tax-Free Corporate Division

Gray Reed on

Disagreements happen.  In the corporate context, one or more shareholders may share a different vision for the company than the other shareholders.  Or, there may be acrimony amongst the shareholders for other reasons, as can...more

Freeman Law

Reviewing Rev. Rul. 2024-14 | Partnership Basis-shifting Transactions, and the Economic Substance Doctrine

Freeman Law on

Introduction - In this revenue ruling, the Service addressed the application of the economic substance doctrine to certain basis-shifting transactions which result from the operative rules of Subchapter K. Generally, the...more

Kilpatrick

5 Key Takeaways - Council On State Taxation (COST) Regional State Tax Seminar

Kilpatrick on

Kilpatrick’s Samantha Breslow, Jordan Goodman, David Hughes, and Jeffrey Reed presented “Discussion of State Tax Cases, Issues & Policy Matters to Watch” and “Where’s Waldo? Sales Sourcing in Today’s SALT World” during the...more

Bowditch & Dewey

Olympic Medals and Income Tax

Bowditch & Dewey on

The 2024 Paris Olympics are in full swing, and it is never too early for U.S. athletes to consult with their tax advisor. As was done in 2021, the United States Olympic & Paralympic Committee has pledged to award U.S....more

Cadwalader, Wickersham & Taft LLP

The Supreme Court Has Saved the Tax Code for Now and Left Room for Moore

Cadwalader, Wickersham & Taft LLP on

In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT), saving a significant portion of the current tax code for now. The question in front of the Court was whether...more

Cadwalader, Wickersham & Taft LLP

Burlington: Good News for the Secondary Debt Market

Cadwalader, Wickersham & Taft LLP on

In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more

Rivkin Radler LLP

Swapping Foreign Real Properties On a Tax Deferred Basis

Rivkin Radler LLP on

Over the last couple of years, several of my friends have become citizens of the country from which their parents emigrated to the U.S. Also during that period, some acquaintances took advantage of the so-called “golden...more

Cadwalader, Wickersham & Taft LLP

IRS Aims to End Abusive Basis-Shifting Transactions

Cadwalader, Wickersham & Taft LLP on

The IRS has issued new guidance to prevent related parties from using partnerships to achieve tax benefits through basis-shifting among assets. The IRS recently released a guidance package aimed at preventing...more

Mayer Brown

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

Mayer Brown on

In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more

Baker Donelson

SALT Select Developments - July 2024

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Bowditch & Dewey

Spousal Relief From Joint Tax Liability

Bowditch & Dewey on

As a general rule, when a married couple files a joint tax return, they are jointly and severally liable for the entire tax. But what happens if one spouse failed to report income and the other spouse did not know or have...more

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

Holland & Knight LLP on

The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

Blake, Cassels & Graydon LLP

Taxe sur les reventes précipitées en Colombie-Britannique : Ce que les propriétaires immobiliers devraient savoir

Blake, Cassels & Graydon LLP on

Lors de la plus récente session parlementaire (et la dernière avant les prochaines élections provinciales), le gouvernement de la Colombie-Britannique a démontré qu’il était toujours résolu à mettre en œuvre son plan intitulé...more

BakerHostetler

[Podcast] Implications of Supreme Court’s Tax Decision in Moore v. United States

BakerHostetler on

A team of BakerHostetler lawyers, led by Partners Andrew Grossman and Jeff Paravano, represented clients Charles and Kathleen Moore at the Supreme Court, arguing that realization is required for federal taxation of income...more

Blake, Cassels & Graydon LLP

B.C.’s Home “Flipping Tax”: What Property Owners Need to Know

Blake, Cassels & Graydon LLP on

The recently concluded legislative session (and the last before the upcoming provincial election) saw continued efforts from the B.C. government to deliver on its “Homes for People” plan, which lays out various government...more

Holland & Knight LLP

Moore Thoughts: An Incremental Opinion from the U.S. Supreme Court

Holland & Knight LLP on

The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more

Morgan Lewis

Government Draft of Annual Tax Act 2024 Adopted

Morgan Lewis on

The Federal Cabinet adopted the government draft of an Annual Tax Act 2024 (JStG 2024) on June 5, 2024. The government draft largely corresponds to the draft bill of May 17, 2024 and contains a large number of very different...more

Gray Reed

IRS Continues Focus On Large Partnerships: 3 Items To Watch Out For

Gray Reed on

In recent years, the IRS has focused its attention and resources on large partnerships. In 2021, the agency launched an initial phase of its Large Partnership Compliance (LPC) program. Under this program, the IRS identified...more

Eversheds Sutherland (US) LLP

Doing less with Moore: Supreme Court upholds section 965 transition tax in Moore v. United States

Eversheds Sutherland (US) LLP on

Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Moore v. United States

Faegre Drinker Biddle & Reath LLP on

On June 20, 2024, the U.S. Supreme Court decided Moore v. United States, No. 22-800, holding that the Mandatory Repatriation Tax (MRT) — a provision in a 2017 tax reform law — could constitutionally impose a one-time...more

Lewis Roca

Supreme Court Decision in Connelly v. United States

Lewis Roca on

On June 6, 2024, the United States Supreme Court issued its decision in in Connelly, As Executor of the Estate of Connelly v. United States, (602 US ________). The decision involves the application of the federal estate tax...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part VII –...

Foster Garvey PC on

In the S corporation arena, tax advisors generally do not focus much attention on unreasonable compensation. As we delve into the issue in this Part VII of my multi-part series on Subchapter S, it will become apparent that...more

995 Results
 / 
View per page
Page: of 40
Next »

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide