Monthly Minute | January 2020
Late in the evening of July 7, 2022, Governor Tom Wolf signed Act 53 of 2022 (Act 53) into law. Act 53 significantly modifies the corporate net income tax (CNIT), subjects certain ride-sharing agreements to sales tax,...more
Massachusetts is already an unattractive state of residency from an estate tax planning perspective because of its low estate tax filing threshold of $1,000,000 per person. Once a person’s adjusted taxable estate is over $1M...more
The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
The 2017 tax reform legislation added section 250 to the Internal Revenue Code, effectively creating a new preferential tax rate for income derived by domestic corporations from serving foreign markets. The new deduction is...more
For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more
Several press articles in recent weeks have anticipated the upcoming enactment of the Ministerial Decree which will eventually implement the Italian Patent Box regime. The Ministry of Economics and Finance announced on 29...more