As reported by Holland & Knight on Dec. 27, 2024, companies and individuals impacted by the Corporate Transparency Act (the CTA) reasonably could have believed there was a respite from the "off again, on again, off again"...more
1/10/2025
/ Appeals ,
Appellate Courts ,
Constitutional Challenges ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
FinCEN ,
Injunctions ,
Petition for Writ of Certiorari ,
Preliminary Injunctions ,
Reporting Requirements ,
SCOTUS ,
Stays
In a continuing series of dizzying judicial actions, the U.S. Court of Appeals for the Fifth Circuit on Dec. 26, 2024, vacated the stay and reinstated the nationwide preliminary injunction enjoining enforcement of the...more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reinstatement ,
Reporting Requirements ,
Stays ,
Time Extensions ,
Vacated
The Corporate Transparency Act (CTA) entered into force on Jan. 1, 2024. Under the beneficial ownership information reporting rule of the CTA, certain entities – such as corporations, limited liability companies and other...more
1/17/2024
/ Beneficial Owner ,
Corporate Governance ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Deadlines ,
Exemptions ,
Final Rules ,
Financial Crimes ,
FinCEN ,
Ownership Interest ,
Regulatory Requirements ,
Reporting Requirements ,
Subsidiaries
Please note: This alert has been updated with new developments after the enactment of the Infrastructure Investment and Jobs Act. The Coronavirus Aid, Relief, and Economic Security (CARES) Act authorized a refundable tax...more
12/7/2021
/ American Rescue Plan Act of 2021 ,
CARES Act ,
Coronavirus/COVID-19 ,
Employee Retention ,
Infrastructure ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Tax Credits ,
Wages
The Coronavirus Aid, Relief, and Economic Security (CARES) Act authorized a refundable tax credit important to many employers struggling as a result of the COVID-19 pandemic. This credit, known as the Employee Retention...more
5/18/2021
/ American Rescue Plan Act of 2021 ,
CARES Act ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Employee Retention ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Tax Credits ,
Time Extensions
The Coronavirus Aid, Relief, and Economic Security (CARES) Act authorized a refundable tax credit important to many employers struggling as a result of the COVID-19 pandemic. This credit, known as the Employee Retention...more
12/30/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Employee Retention ,
Federal Loans ,
Financial Stimulus ,
Nonprofits ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business ,
Tax Credits
The Internal Revenue Service (IRS) on July 31, 2020, published proposed regulations (Proposed Regulations) on the tax treatment of certain partnership interests held in connection with the performance of services (such...more
The Global Intangible Low-Taxed Income (GILTI) provisions were enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA). Under the GILTI provisions, a U.S. shareholder essentially is taxed on the active earnings of a...more
The coronavirus (COVID-19) health crisis and associated economic downturn is expected to have a significant impact on commercial real estate lessees, as their ability to attract in-person customers and otherwise generate...more
A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more
The Internal Revenue Service (IRS) has provided taxpayers with needed relief by delaying the due dates with respect to various filings and payments during the coronavirus (COVID-19) pandemic. This relief has been announced in...more
As a result of the coronavirus (COVID-19) pandemic, several legislative and regulatory measures have been promulgated in an effort to assist businesses during the economic downturn. Below is a summary of the most important...more
• The U.S. Department of the Treasury has released proposed regulations dealing with the application of the recent U.S. tax reform to U.S. shareholders of a "controlled foreign corporation" (CFC).
• A foreign corporation...more
3/6/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Earned Income ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Proposed Regulation ,
Shareholders ,
Stock Ownership ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
• The Internal Revenue Service has issued a proposed regulation that in many cases should eliminate the detrimental U.S. tax consequences to a U.S. corporation under Section 956 of the Internal Revenue Code when the...more
11/9/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
Tax Cuts and Jobs Act
President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more
1/3/2018
/ Base Erosion Tax ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Dividends ,
EBITDA ,
Estate Tax ,
Foreign Corporations ,
Foreign Subsidiaries ,
Foreign Taxpayers ,
Income Taxes ,
International Tax Issues ,
IRS ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Royalties ,
Shareholders ,
Small Business ,
Subsidiaries ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Withholding Tax
President Donald Trump signed the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on January 1, 2018 (generally until 2025).
The...more
12/28/2017
/ Carried Interest ,
Corporate Taxes ,
Estate Tax ,
Income Taxes ,
Like Kind Exchanges ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Property Owners ,
Real Estate Development ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration
Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more
12/20/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Depreciation ,
Dividends ,
Estate Tax ,
Foreign Subsidiaries ,
Gift Tax ,
GST ,
Income Taxes ,
IRS ,
Itemized Deductions ,
Net Operating Losses ,
Pass-Through Entities ,
Personal Exemptions ,
Proposed Legislation ,
Section 199 ,
Shareholders ,
Standard Deduction ,
Subpart F ,
Tax Code ,
Tax Credits ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
It has been a busy week in Washington, D.C., as Congress works its way through tax reform. The House Ways and Means Committee completed its "markup" of the House bill this week, paving the way for a floor vote on the measure...more
11/13/2017
/ Alternative Minimum Tax ,
Business Tax Credits ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Death Tax ,
Depreciation ,
Dividends ,
Estate Tax ,
Foreign Corporations ,
Foreign Subsidiaries ,
Gift Tax ,
GST ,
Itemized Deductions ,
Markups ,
Net Operating Losses ,
Pass-Through Entities ,
Personal Exemptions ,
Section 199 ,
Standard Deduction ,
Subpart F ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Ways and Means Committee
With Republicans in control of the U.S. Senate, the U.S. House of Representatives and the White House starting in 2017, the federal government is now better positioned to move forward on comprehensive tax reform, with...more
11/29/2016
/ Alternative Minimum Tax ,
Business Taxes ,
Capital Gains ,
Corporate Taxes ,
Depreciation ,
Estate Tax ,
Foreign Subsidiaries ,
Gift Tax ,
GST ,
Life Insurance ,
Mortgage Interest ,
Net Investment Income ,
Net Operating Losses ,
Personal Exemptions ,
S-Corporation ,
Subpart F ,
Tax Credits ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The Protecting Americans from Tax Hikes Act of 2015 (PATH Act) was signed into law on Dec. 18, 2015, as part of the Consolidated Appropriations Act, 2016. The PATH Act alters the regime for taxing foreign persons holding U.S....more
The Bipartisan Budget Act of 2015 (P.L. 114-74) includes a complete overhaul of the procedures that apply to Internal Revenue Service (IRS) audits of partnerships, including limited liability companies (LLCs) taxed as...more
Lately, the media has focused on tax inversions, most recently when Burger King announced that it will purchase Tim Hortons, a Canadian company, but what are they?...more
HIGHLIGHTS -
- The IRS has issued a Notice detailing temporary modifications to its enforcement rules having to do with the Foreign Account Tax Compliance Act.
- Under IRS Notice 2014-33, 2014 and 2015 will be...more
At midnight on December 31, 2012, the United States briefly fell off of the much-anticipated and highly publicized "fiscal cliff," with income tax rates rising on most taxpayers and a host of substantial spending cuts...more