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BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman David Schweikert, R-AZ

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy and political debates in Congress. In this episode of “The Cloakroom with...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman Brendan Boyle, D-PA

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy debates in Congress. In this episode of “The Cloakroom with Peter Roskam,”...more

DarrowEverett LLP

Maximizing QSBS Benefits with Estate Planning: The Art of Stacking

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The number of taxpayers seeking the benefits of Qualified Small Business Stock (“QSBS”) has picked up steam in recent years, particularly since the Tax Cuts and Jobs Act (“TCJA”) lowered the federal corporate tax rates to...more

Holland & Knight LLP

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

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The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...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 II – Code...

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This second installment of my multi-part series on Subchapter S is focused on two Code Sections, namely IRC Section 1375 and IRC Section 1362(d)(3)....more

Rivkin Radler LLP

Nothing Lasts Forever –Expiring Tax Provisions

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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

Burns & Levinson LLP

Death and Taxes – The Three Unavoidable Taxes in Estate Administration

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Death and taxes are often jokingly said to be two of the only unavoidable things in life. Unfortunately, taxes are also unavoidable when someone passes away. When administering an estate or trust after someone’s death, three...more

Foodman CPAs & Advisors

¿Impuestos Adeudados Pero NO Pagados En Su Totalidad? El IRS Cobra El 8%.

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El 8/25/23, el IRS anunció que el aumento de las tasas de interés para el cuarto trimestre del 2023 aumentaría al 8% anual para el trimestre calendario que comienza el 10/1/23 para los impuestos adeudados pero no pagados en...more

Bowditch & Dewey

Big Increase in 2024 Estate Exemption – IRS Issues 2024 Inflation Adjustments

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The IRS recently issued the 2024 annual adjustments for numerous tax provisions, including changes to tax brackets and standard deductions. Popular adjustments include...more

Allen Barron, Inc.

IRS to Leave More in Our Paychecks in 2024

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Is it possible for the IRS to leave more in our paychecks in 2024? What has changed for the 2024 federal income tax brackets and how will these apply to the tax return(s) you’ll file in 2025?...more

Allen Barron, Inc.

The High IRS Tax Rates on a Foreign Trust

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Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more

Goulston & Storrs PC

Biden’s FY2024 Budget: Key Real Estate Tax Proposals

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On March 9, 2023, President Biden released his FY2024 budget (the “FY2024 Budget”), and the U.S. Treasury released the so-called “Green Book," which provides details related to the revenue provisions in the FY2024 Budget....more

Brownstein Hyatt Farber Schreck

Taxation & Representation. Feb. 15, 2023

TAX TIDBIT - Progress on Werfel and Blatchford Appointments, Other Nominations Delayed. Following the retirement of former IRS Commissioner Chuck Rettig in early November 2022, the tax-administration agency has been...more

Bowditch & Dewey

Tax Year 2023 Annual Inflation Adjustments

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The Internal Revenue Service has announced the tax year 2023 annual inflation adjustments for more than 60 tax provisions including tax rate schedules and other tax changes. Here are some key highlights...more

Eversheds Sutherland (US) LLP

Signed, sealed, delivered: Biden signs Inflation Reduction Act enacting “new” corporate minimum tax

​​​​​​​On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more

Dechert LLP

Another Stab at Carried Interests Under the Inflation Reduction Act of 2022

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On July 27, 2022, Senator Joe Manchin III (D-W.Va.) and Majority Leader Charles E. Schumer (D-N.Y.) introduced legislation entitled the “Inflation Reduction Act of 2022” (the “Reconciliation Bill”). The Reconciliation Bill is...more

A&O Shearman

Inflation Reduction Act of 2022: New Corporate Book Minimum Tax and Changes for Carried Interests

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On July 27, 2022, Senators Manchin and Schumer announced that they agreed to a proposed reconciliation package, the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”). If enacted, the Bill would finance climate programs,...more

Proskauer - Tax Talks

The Biden Administration Re-Proposes to Tax Carried Interests as Ordinary Income

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On March 28, 2022, the Biden Administration proposed to tax “profits” or “carried” interests as ordinary income and impose self-employment tax on income and gains from these interests for certain partners in investment...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, April 26, 2022

SCOTUS Denies New York v. Yellen. The U.S. Supreme Court announced on Tax Day it would not hear a constitutional challenge to the $10,000 deduction limit on state and local taxes (SALT) enacted under the Tax Cuts and Jobs Act...more

Baker Donelson

SALT Select Developments - April 2022

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain SALT developments in several...more

Lasher Holzapfel Sperry & Ebberson PLLC

Washington’s New Capital Gains Tax is Overturned as Unconstitutional

In 2021, Washington State Legislature passed ESSB 5096, which created a 7% tax on the sale or exchange of long-term capital assets (stocks, bonds, business interests, or other investments, and many tangible assets) if the...more

Freeman Law

Tax Treaty-Based Return Reporting Disclosures

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A taxpayer taking a treaty-based return position is generally required to disclose that position, unless an exception applies. A treaty-based return position is a tax reporting position, maintaining that a U.S. tax treaty...more

Miller Nash LLP

Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies

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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

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On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Cooley LLP

What is a Section 83(b) Election and Why Should You File One?

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Update: on April 15, 2021, the Internal Revenue Service announced that it would temporarily (through December 31, 2021) allow Section 83(b) elections to be signed digitally or electronically, instead of requiring handwritten...more

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