The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax
Employee Benefits and Executive Compensation: Getting Ready for 2024 - Qualified Plans — Special Edition Podcast
End of Year Tax Planning: Tips for Healthcare Professionals and Practices
Change of Control: Golden Parachute Rules in the Sale Process
4 Key Takeaways | Mid-Year Tax Update
TELL ME SOMETHING GOOD! Planning for Post-Retirement Medical Expenses with 401(h) Plans
TELL ME SOMETHING GOOD! Planning for Post-Retirement Medical Expenses With 401(h) Plans
NOWOTNY KNOWS SQUAT! Part IV Using Post-Retirement Medical Plans to Raise AUM and Sell Life Insurance
NOWOTNY ON DEATH AND TAXES EPISODE 35 USING POST-RETIREMENT MEDICAL PLANS TO RAISE AUM
COVID-19 Relief in 2021: What Small Businesses Need to Know
The Biden Tax Plan
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!
KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!
The Freeman Law Project – Episode 21 – The New York Times and President Trump's Taxes
ROCK OF AGES video
On-Demand Webinar | PPP Loan Forgiveness: Employment and Tax Issues for Borrowers
THE SPLIT DOLLARMINATOR!
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
The UK’s First-tier Tribunal (“FTT”) has denied a taxpayer a deduction for contributions to a remuneration trust on the basis that such payments did not give rise to an expense under generally accepted accounting principles...more
A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...more
A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more
On Aug. 7, the Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the Act). If approved by the House of Representatives, as expected, the bill will be sent to President Joe Biden for signature. The bill passed by...more
Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more
Tax Staffers Discuss State of Tax Policy. At a tax conference last week, top officials from the Biden administration and key congressional staffers discussed the latest in tax policy. One panel, which was focused on the...more
Le 7 avril 2022 (le « jour du Budget »), la ministre des Finances du Canada a présenté le budget fédéral de 2022 (le « Budget 2022 »). Certains contribuables ont peut-être été soulagés de constater que le Budget 2022 ne...more
On April 7, 2022 (Budget Day), the Minister of Finance introduced Canada’s 2022 Federal Budget (Budget 2022). While taxpayers may be relieved that Budget 2022 does not include an increase to the capital gains inclusion rate...more
UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more
Durante el 2022 debemos contemplar ciertas obligaciones en este año así como nuevas disposiciones de interés para las OSC en diversas materias. Es importante que las revises para que cumplas con todos los requisitos que pide...more
Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation....more
Senate Finance Committee Democrats Update Build Back Better. On Saturday afternoon, Senate Finance Committee Chair Ron Wyden (D-OR) released legislative text for the committee’s portion of the Build Back Better Act. The text...more
È prevista l'abrogazione del Patent Box e l'introduzione di una nuova opzione per la maggiore deducibilità del 90% dei costi di ricerca e sviluppo sui beni immateriali alternativa al credito d’imposta per attività di ricerca,...more
The tax decree October 21, 2021 no.146 provided the abolishing of the Patent Box regime and the introduction of a new optional regime providing an extra deduction (for Corporate income tax purposes as well as for the Regional...more
The Chancellor presented the Budget on 27 October. Although it contained a wide range of general spending and tax-related announcements, there was nothing of significance for the private funds industry that had not been...more
Negotiations Update. After months of negotiation, Democrats appear close to an agreement between the White House, progressives and influential moderate Sens. Joe Manchin (D-WV) and Kyrsten Sinema (D-AZ) on budget...more
TAX TIDBIT - Where In the Tax World Are Manchin and Sinema? The contents and scope of the Build Back Better Act—the budget reconciliation measure through which congressional Democrats are attempting to enact most of...more
Tax Court Cases: The Week of August 30 – September 3, 2021 - Karson C. Kaebel v. Comm’r, No. 16171-18P, T.C. Memo 2021-109 | September 9, 2021 | Halpern | Dkt. No. 16171-18P - Tax Dispute Short Summary: This case focuses on...more
In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 16 – August 20, 2021 - Catlett v. Comm’r, No....more
On May 28, 2021, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for FY...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more
Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more