On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more
5/29/2025
/ Business Taxes ,
Corporate Taxes ,
Estate Tax ,
Federal Budget ,
Gift Tax ,
GILTI tax ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Local Taxes ,
New Legislation ,
Popular ,
SALT ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Taxation
On December 26, 2024, the Fifth Circuit merits panel assigned to Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, reinstated a nationwide preliminary injunction enjoining enforcement of the Corporation Transparency Act and...more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Vacated
This alert has been updated to reflect FinCEN’s extension of the deadline after the alert was first sent.
On December 23, 2024, after expedited briefing, a three-judge panel of the Fifth Circuit in Texas Top Shop v....more
12/24/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Time Extensions
The Corporate Transparency Act (CTA) and its implementing regulations (Regulations) require entities within its scope (reporting companies) to disclose information, including about their beneficial owners, to the U.S....more
12/16/2024
/ Business Ownership ,
Corporate Counsel ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Suspended Judgment ,
Unconstitutional Condition
The Corporate Transparency Act and its implementing regulations (together CTA) came into effect on January 1, 2024, requiring entities within its scope to disclose information, including about their beneficial owners, to the...more
2/2/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Governance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
New York ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On September 8, 2023, Internal Revenue Service (IRS) Commissioner Danny Werfel announced the rollout of a coordinated enforcement strategy that will involve audits of returns filed by 75 of the largest partnerships operating...more
9/13/2023
/ Enforcement Actions ,
Estate Planning ,
Inflation Reduction Act (IRA) ,
Investment Management ,
IRS ,
Offshore Funds ,
Partnerships ,
Private Equity ,
TEFRA ,
Trustees ,
Wealth Tax
On March 9, 2023, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for...more
3/20/2023
/ Biden Administration ,
Corporate Taxes ,
Estate Tax ,
Federal Budget ,
Gift Tax ,
GILTI tax ,
Green Book ,
Income Taxes ,
International Tax Issues ,
Partnerships ,
Property Tax ,
Retirement ,
Tax Reform ,
U.S. Treasury
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
6/15/2021
/ Biden Administration ,
Capital Gains Tax ,
Corporate Taxes ,
Energy Tax Incentives ,
GILTI tax ,
Green Book ,
Income Taxes ,
International Tax Issues ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
Democratic presidential nominee Joe Biden has provided limited information about his plans to modify the tax treatment of decedents and their estates. However, he has signaled that he supports raising estate taxes and...more
10/4/2020
/ Capital Gains ,
Estate Planning ,
Estate Tax ,
Estate-Tax Exemption ,
Gift Tax ,
Gift-Tax Exemption ,
High Net-Worth ,
Joe Biden ,
Popular ,
Presidential Elections ,
Proposed Rules ,
Tax Rates ,
Tax Reform
Former Vice President Joseph Biden has proposed a number of fundamental changes to the tax code over the course of his campaign. If he is elected president and if the Democrats keep control of the House of Representatives and...more
9/24/2020
/ Alternative Minimum Tax ,
Capital Gains ,
Capital Gains Tax ,
Corporate Taxes ,
Estate Tax ,
GILTI tax ,
Joe Biden ,
Like Kind Exchanges ,
Offshore Funds ,
Presidential Elections ,
Retirement Plan ,
Social Security Taxes ,
Tax Credits ,
Tax Policy ,
Tax Rates ,
Tax-Deferred Exchanges
On March 27, 2020, the Coronavirus Aid, Relief and Economic Security Act (CARES Act) was signed into law. The act, which provides assistance to individuals and businesses in response to the COVID-19 pandemic, increases the...more
The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...more
6/20/2018
/ CFCs ,
Controlled Foreign Corporations ,
Cross-Border Transactions ,
Estate Planning ,
Estate Tax ,
Foreign Corporations ,
Foreign Subsidiaries ,
Generation-Skipping Transfer ,
Gift Tax ,
Gifts ,
GILTI tax ,
Grace Period ,
High Net-Worth ,
Inbound Investments ,
Partnerships ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform ,
Transition Tax
The newly enacted U.S. tax law makes significant changes to provisions of the Internal Revenue Code affecting high net worth individuals, their investment entities and family offices. These changes are likely to spur gift...more
1/24/2018
/ Corporate Conversions ,
Estate Planning ,
Estate Tax ,
Family Businesses ,
Generation-Skipping Transfer ,
Gift Tax ,
High Net-Worth ,
Income Taxes ,
Pass-Through Entities ,
Revocable Trusts ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Reform ,
Trusts