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Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck [Audio]

TRAs can be advantageous if used properly. When you get numbers in front of people in the right situation, it catches their attention. The key is to get people focused and make sure they understand the complexities. In this...more

Supreme Court Confirms Retaliatory Intent Is Irrelevant in Proving SOX Retaliation

On February 8, 2024, in its Murray v. UBS Securities, LLC1 opinion, the U.S. Supreme Court unanimously held that a whistleblower pursuing a claim for retaliation under the Sarbanes-Oxley Act of 2002 (“SOX”) does not need to...more

Fifth Circuit Upholds Nasdaq Board Diversity Rule

On October 25, a panel of the Fifth Circuit Court of Appeals (the “Fifth Circuit”) upheld the Nasdaq board diversity rule in the face of challenges that (among other things) the rule attempted to improperly and...more

The Heat Is on for Large Partnership Audits

Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more

IRS Internal Memorandum Questions NIL Collectives’ 501(c)(3) Tax-Exempt Status

The IRS recently issued an internal memorandum to the effect that many Name-Image-Likeness (NIL) collectives will not qualify for 501(c)(3) tax-exempt status, including those that had previously obtained tax exemption letters...more

Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax

On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was enacted into law. Among other changes to the Internal Revenue Code of 1986, as amended (the “Code”), the IRA imposes a 15% corporate alternative minimum...more

Inflation Reduction Act of 2022: Excise Tax on Repurchases of Corporate Stock and Interesting Applications to SPACs

On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was enacted into law. Among other changes to the Internal Revenue Code of 1986, as amended (the “Code”), the IRA imposes an excise tax on certain repurchases...more

Introducing The Up-SPAC Structure

As the pace of SPAC IPOs continues to set records, evolution of the economic terms has accelerated. We have seen changes to the warrant and promote structure (including “tontine” warrants), call rights motivating cashless...more

[Webinar] All in the Family: Applying the Business Interest Expense Limitation Within Groups - September 30th, 12:00 pm - 1:00 pm...

The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more

[Webinar] Navigating Challenging Times: Tax Opportunities - June 4th, 12:00 pm - 1:15 pm CT

Uncertain economic times and volatile financial markets present pitfalls — but also opportunities. We’ll talk about tax planning opportunities businesses should consider as they navigate these challenging times....more

[Webinar] Tax in the COVID-19 Era: CARES Act Tax Relief and IRS Guidance - May 6th, 12:00 pm - 1:15 pm CT

CARES Act tax relief is designed to put cash in the pockets of taxpayers in distress. In this presentation, a panel of V&E’s tax and executive compensation lawyers will discuss how to maximize the benefit of these provisions,...more

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