News & Analysis as of

Tax Loopholes

Allen Barron, Inc.

What is the “Abusive Use of Partnerships” and Why does the IRS Care?

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What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more

Pillsbury Winthrop Shaw Pittman LLP

FCC Closes Lead Generator Loophole, Strengthens Illegal Text Message Blocking and Lays Groundwork for Future Additional Blocking...

New rules build on text message delivery restrictions put in place earlier this year and are informed by the Federal Communications Commission’s ongoing work against illegal robocalls. The Federal Communications Commission...more

Goodwin

Massachusetts Doubles Estate Tax Exemption as Part of $1 Billion Tax Bill

Goodwin on

Massachusetts has passed a sweeping $1 billion tax relief package intended to boost the Commonwealth’s affordability and competitiveness. Among other changes, the tax bill doubles the Massachusetts estate tax exemption to $2...more

Bowditch & Dewey

Massachusetts Tax Reform Enacted – Estate Tax Exemption Increase and Other Help for Residents

Bowditch & Dewey on

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

Bowditch & Dewey

Cryptocurrency Wash-Sale Loss Harvesting

Bowditch & Dewey on

The IRS wash-sale rule does not currently apply to cryptocurrency because the IRS considers virtual currencies to be property rather than securities. In general, a taxpayer who exchanges cryptocurrency for goods, services or...more

Foodman CPAs & Advisors

EL FATCA “Loophole” Traerá Más Acciones De Cumplimiento

Foodman CPAs & Advisors on

Después de una investigación de un año, el Comité de Finanzas del Senado de los EE. UU. investigó una escapatoria (FATCA Loophole) y entregó un Reporte de investigación titulado “The Shell Bank Loophole” que expone un esquema...more

Foodman CPAs & Advisors

The FATCA Loophole Will Bring More Enforcement Action

After a yearlong investigation, the US Senate Finance Committee probed into a FATCA Loophole and delivered an investigative report titled “The Shell Bank Loophole” that exposes a tax evasion scheme under a FATCA loophole...more

Proskauer Rose LLP

UK Tax Round Up - September 2022

Proskauer Rose LLP on

Welcome to September’s edition of the UK Tax Round Up. In addition to the headline-grabbing 2022 Growth Plan announced by the UK Chancellor, there have been a number of interesting cases this month including the First-tier...more

Whitman Legal Solutions, LLC

Tax Treatment of Carried Interests Not Likely to Change This Year

Just over a week ago, in Changes to Tax on Carried Interest Would Lead to Conflicts of Interest, I wrote about a proposal in Congress to modify the tax laws relating to carried interests. However, now like Ko-Ko, carried...more

Rivkin Radler LLP

The Schumer-Manchin Proposal To “Eliminate” the Profits Interest

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Summer Break? After the last couple of weeks, I’m looking forward to Congress’s summer vacation. I’m pretty sure our elected representatives feel the same way, though it is unclear at this point when they will be heading...more

Jackson Lewis P.C.

Inflation Reduction Act of 2022 Aims to Close Carried Interest Loophole

Jackson Lewis P.C. on

Earlier this week, Senators Manchin and Schumer reached an agreement securing the former’s support for a tax bill proposed by Senate Democrats entitled the “Inflation Reduction Act of 2022” (the “Act”). Included in the Act...more

Holland & Knight LLP

Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming

Holland & Knight LLP on

Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap in the U.S. may total $1 trillion per year. In his view, the increase from prior estimates is due, in part,...more

King & Spalding

The Impact of COVID-19 on Nuclear Electricity Sales Contracts in France

King & Spalding on

The electricity sector, like numerous others in France, has been heavily affected by the economic shutdown due to the COVID-19 pandemic. The first two weeks of confinement led to a reduction in electricity consumption in...more

Whitman Legal Solutions, LLC

Sizing Up in Violins and Investment Real Estate | Orchestrating Real Estate

If you have ever attended an elementary school instrumental music concert, you may need your parental pride to outweigh the general cacophony that is inflicted on your ears. Sometimes, however, you may find a group of violins...more

Akerman LLP

Episode 26: Talking Tax Reform and Executive Comp

Akerman LLP on

Don’t let the episode title scare you away! Matt welcomes colleague Leanne Reagan to discuss how the House’s proposed tax reform bill impacts compensation arrangements and how, if passed into law, it could completely...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 2

Governor Cuomo Releases 2017-18 New York State Executive Budget - New York State Governor Andrew M. Cuomo released his 2017-2018 Executive Budget, containing an assortment of potentially important tax proposals,...more

Foley & Lardner LLP

U.S. PFIC Taxation Exemption to be Narrowed?

Foley & Lardner LLP on

The last 15 years have seen the advent of a new reinsurance platform, where hedge funds have sponsored non-U.S. reinsurers, who in turn invest their capital in the sponsoring hedge funds. While there are business rationales...more

McDermott Will & Emery

Hybrid Mismatches – UK Proposals for Implementing the BEPS Recommendations

McDermott Will & Emery on

The United Kingdom made its first substantive commitment arising out of the base erosion and profit shifting (BEPS) initiative on 3 December 2014, with the release of a consultation paper on implementing the agreed G20-...more

Moore & Van Allen PLLC

The Eye of the Beholder

Moore & Van Allen PLLC on

“A tax loophole is something that benefits the other guy. If it benefits you, it is tax reform.” – former U.S. Senator Russell B. Long (D – Louisiana). “The precise point at which a tax deduction becomes a ‘loophole’...more

Broker-Dealer Compliance + Regulation

Division of Investment Management Closes Loophole for Fund Advisers Providing Interim Services “At Cost”

The SEC’s Division of Investment Management has closed a potential loophole in the federal securities laws through which some fund advisers may have attempted to squeeze to avoid registration....more

Ballard Spahr LLP

Significant Pennsylvania Tax Changes

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The General Assembly made significant changes to a number of Pennsylvania taxes as part of the 2013-2014 budget process. These changes were enacted in Act 52, signed into law on July 9, 2013, and have various effective dates....more

King & Spalding

Investing In Georgia: Economic Development Newsletter - February 2013

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In This Issue: Welcome to King & Spalding's economic development news bulletin,Investing in Georgia. In this edition, you will find: - An overview of the sequester, debt ceilings, continuing resolutions to fund...more

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