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
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
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
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
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 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
3/12/2020
/ Affiliated-Business Arrangements ,
Appeals ,
Bob Richards Rule ,
Commercial Bankruptcy ,
Consolidated Tax Returns ,
Federal Common Law ,
Federal v State Law Application ,
IRS ,
Jurisdiction ,
Lack of Authority ,
Parent Corporation ,
Remand ,
Rodriguez v Federal Deposit Insurance Corp. ,
SCOTUS ,
State Law Claims ,
Tax Allocation Agreements ,
Tax Refunds ,
Vacated
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
12/3/2019
/ Bitcoin ,
Blockchain ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Filing Requirements ,
Financial Transactions ,
Income Taxes ,
Investment ,
IRS ,
New Guidance ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Virtual Currency
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
4/25/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives
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
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
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
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
1/2/2018
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Business Taxes ,
Compensation & Benefits ,
Corporate Taxes ,
Executive Compensation ,
Income Taxes ,
International Tax Issues ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Section 162(m) ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
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