In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more
As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us.
Review of U.S. Tax Developments in 2022-
In 2022 we...more
With another new year nearly upon us, we call attention to regulatory changes to the Stock Buyback Excise Tax that will be proposed to take effect on January 1 and the implications on more non-U.S. corporations. Specifically,...more
The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments,...more
8/18/2022
/ Biden Administration ,
Carried Interest ,
Climate Change ,
Corporate Taxes ,
Enforcement ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
IRS ,
New Legislation ,
Portfolio Companies ,
Share Buybacks ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Wealth Tax
Review of U.S. Tax Developments in 2021-
Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more
3/4/2022
/ Anti-Injunction Act ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
BEPS ,
Capital Gains ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
Infrastructure ,
IRS ,
Joe Biden ,
Like Kind Exchanges ,
Net Investment Income ,
OECD ,
PFIC ,
Popular ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Tax Treaty ,
U.S. Treasury
The U.S. House Committee on Rules recently released an updated version of the Build Back Better Act (Act) to reflect the White House’s Build Back Better framework (Framework) announced on the same day (October 28, 2021). ...more
11/9/2021
/ Alternative Minimum Tax ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
Corporate Taxes ,
Excise Tax ,
Foreign Investment ,
GILTI tax ,
High Net-Worth ,
Income Taxes ,
Share Buybacks ,
Tax Credits ,
Tax Planning ,
Tax Rates ,
Tax Reform