Nonprofit Quick Tip: State Filings in Massachusetts and Connecticut
EV Tech Series: The Inflation Reduction Act’s Impact on the Energy Industry With Judy Kwok and Marc Machlin - Battery + Storage Podcast
Tribal Tax Exemption Under McGirt Gains Preliminary Victory
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
ATTENTION ALL CADETS!
One Note Samba
Podcast: State Taxation of Digital Health Products
Investment Management Roundtable Discussion – Personal Estate Planning
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Episode 26: Talking Tax Reform and Executive Comp
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
New York Estate Tax Law Changes
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
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
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
Individuals considering moving to the United States should be aware of the tax consequences of becoming a U.S. resident and take advantage of tax planning opportunities before moving here. George McCormick discusses these...more
I seem to have been on a writing sabbatical for the last year. Over the course of the year, I have discovered a few new planning ideas to share going forward. From previous articles you already know that I grew up in the...more
Seyfarth Synopsis: To bring Hong Kong’s Foreign-Sourced Income Exemption (FSIE) regime in line with the European Union’s updated guidance on FSIE regimes promulgated in December 2022, the Inland Revenue (Amendment) (Taxation...more
June 2024 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The June Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs...more
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
In late March 2024, in the case of Donna Buettner-Hartsoe v. Baltimore Lutheran High School Association, the U.S. Court of Appeals for the Fourth Circuit considered whether exemption from federal income tax under Internal...more
As the ball drops in Times Square on December 31, 2024, many of the tax breaks established by the Tax Cuts and Jobs Act (TCJA) of 2017 will disappear. While the TCJA made some permanent tax cuts, a number of tax cuts and...more
In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more
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
TYPES OF BUSINESS ENTITIES - In the Netherlands, there is a distinction between entities which qualify as legal entities (‘rechtspersonen’) and partnerships (‘personenvennootschappen’) which do not. Legal entities are...more
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
2023 saw a number of key tax developments that may affect the private fund industry going into 2024, from key US Tax Court opinions and updates to Internal Revenue Service (IRS) Forms, to new regulations proposed by the IRS...more
The Long-Term View- Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole. ...more
1. Types of Business Entities - The most common types of companies in Estonia are the public limited liability company ("AS") and the private limited liability company ("OÜ"). The OÜ may be compared to a closed...more
Beginning January 1, 2024, many types of legal entities must report information regarding their “beneficial owners” and certain other information (collectively, “BOI”) to the Financial Crimes Enforcement Network (“FinCEN”)....more
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
It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more
For many weeks, we’ve been hearing about the IRS’s plans to use the funding provided under the Inflation Reduction Act[i] to increase and expand its compliance and enforcement efforts with respect to the wealthy, high-income...more
If you own your principal residence, you may be able to benefit from its build-up in equity, realize current tax breaks and pocket a sizeable tax-exempt gain when you sell it. What’s more, from an estate planning perspective,...more
The long-awaited Massachusetts tax reform package was signed by Governor Maura Healey on Wednesday, October 4, 2023. Among the provisions: Estate Tax Reform: Establishes a non-refundable credit of $99,600 for each estate,...more
Estate planning professionals help clients look ahead and anticipate future contingencies. By necessity, however, estate plans are crafted based on laws and circumstances existing at the time they are put in place. This...more