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US-Chile Bilateral Income Tax Treaty Enters Into Force

On Dec. 19, 2023, Treasury announced the entry into force of the U.S.-Chile bilateral income tax treaty (the Tax Treaty). The Tax Treaty is the first new comprehensive bilateral tax treaty signed by the United States to enter...more

US-Chile Income Tax Treaty Approval Process Continues

On Oct. 25, the Chilean government submitted the reservations made by the U.S. Senate regarding the U.S.-Chile bilateral income tax treaty (the Tax Treaty) to the Chilean Congress for approval. Chilean tax practitioners...more

M&A Structuring Opportunities Utilizing State Level Pass-Through Entity Tax Regimes

State-level pass-through entity tax (PTET) regimes offer structuring opportunities in M&A transactions involving S corporation targets. PTET regimes have been adopted by a growing number of states as a workaround to the...more

Treasury Extends April 15 Income Tax Payment and Filing Deadline

Updated: April 1, 2020 - The IRS announced on March 20 in Notice 2020-18 that the due dates for (i) filing federal income tax returns and making federal income tax payments with respect to 2019 that are otherwise due on...more

Tax-Related Provisions of Senate Economic Relief Bill

On March 19, Senate Majority Leader Mitch McConnell introduced in the Senate a bill called the Coronavirus Aid, Relief, and Economic Security Act, or CARES Act. The bill includes several tax-related provisions that are...more

In Decision With Important Tax and Bankruptcy Implications, Supreme Court Rejects Application of So-Called 'Bob Richards Rule'

In its recent decision in Rodriguez v. Federal Deposit Insurance Corp., No. 18–1269 (Sup. Ct. Feb. 25, 2020), the Supreme Court held that federal courts may not apply the federal common law “Bob Richards Rule” to determine...more

Virtual Currency

On Oct. 9, 2019, the Internal Revenue Service (the “Service”) issued Revenue Ruling 2019-24 concerning the tax consequences of virtual currency hard forks, as well as FAQs on the taxation of virtual currency generally. This...more

IRS Issues Additional Proposed Regulations on Qualified Opportunity Zones

On Dec. 22, 2017, the Qualified Opportunity Zone tax incentive program was signed into law as part of the Tax Cuts and Jobs Act of 2017....more

Important Changes To NYS Transfer and Mansion Taxes

As part of the 2020 budget, the New York State Senate and Assembly enacted new revenue legislation, which included an increase to New York State’s transfer tax and mansion tax on transfers of real property. ...more

A Qualified Opportunity Fund or a 1031 Exchange? Timing Is Key

The 2017 Tax Cuts and Jobs Act created new tax incentives for investing in the U.S. Among these is an opportunity to defer capital gains tax by reinvesting such gains in qualified opportunity funds (QOFs). ...more

Tax and Cryptocurrencies

The meteoric rise of cryptocurrencies has created a stir in the financial and investment communities. The Securities and Exchange Commission, along with other regulatory bodies, is taking an active role in policing and...more

Tax Reform

On Dec. 22, 2017, President Trump signed into law tax reform legislation (“the Act”) that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal...more

Funds Talk: September 2017 - Tax Court Declines to Follow Rev. Rul. 91-32

In a recent decision, Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, the U.S. Tax Court declined to follow Revenue Ruling 91-32, and held that gain on the sale of an interest in an operating...more

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