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Gerald Nowotny - Law Office of Gerald R....

Hooked on a Feeling! The Benefits of 501(c)(4) Charitable Organizations

I seem to have been on a writing sabbatical for the last year. Over the course of the year, I have discovered a few new planning ideas to share going forward. From previous articles you already know that I grew up in the...more

McGuireWoods LLP

Federal Adaptive Reuse Bill Introduced in House of Representatives

McGuireWoods LLP on

U.S. Reps. Mike Carey (R-OH) and Jimmy Gomez (D-CA) introduced the bipartisan “Revitalizing Downtowns and Main Streets Act” in the House of Representatives on July 12, 2024. Modeled after the Historic Preservation Tax Credit,...more

Freeman Law

Centralized Partnership Audit Regime (CPAR) and a Trap for the Unwary

Freeman Law on

Centralized Partnership Audit Regime (CPAR) is a somewhat new regime that followed TEFRA. Congress promulgated CPAR as part of the Bi-partisan Budget Act of 2015. For taxable years beginning in 2018, CPAR is the controlling...more

Cadwalader, Wickersham & Taft LLP

Finally Final Crypto Reporting Regulations

On June 28, 2024, the Treasury and the IRS released final regulations on reporting requirements for brokers of digital assets (the “Final Regulations”) and provided transitional relief, including Notice 2024-56, Notice...more

Cadwalader, Wickersham & Taft LLP

Supreme Court Overruling of Chevron Fuels Regulatory Uncertainty

On June 28, the U.S. Supreme Court sent shockwaves through the legal system by overturning one of the foundational precedents of American administrative law.  In Loper Bright Enterprises v. Raimondo, the Court, in a 6-3...more

Bressler, Amery & Ross, P.C.

Adverse Estate Tax Impact when a Redemption Agreement is used to Purchase Deceased Shareholder’s Shares

In the recent case, Connelly v. United States, 602 U.S. (2024) (slip op.) the U.S. Supreme Court unanimously ruled that life insurance proceeds received by a closely held corporation which is used to fund the redemption of a...more

Goulston & Storrs PC

D.C. FY25 Budget Expands CRE Revitalization Initiatives

Goulston & Storrs PC on

The end of June saw the D.C. Council pass the Fiscal Year 2025 Budget Support Act of 2024 and the Fiscal Year 2025 Local Budget Act of 2024. The 2025 budget includes the “Central Washington Activation Conversion Program...more

Dorsey & Whitney LLP

Commerce Proposes Wide-Ranging Regulations for Antidumping and Countervailing Duty Proceedings, With Reduced Court Deference...

Dorsey & Whitney LLP on

The U.S. Department of Commerce (“Commerce”) earlier this month proposed a set of wide-ranging revisions and additions to its regulations (i.e., the “Proposed Rule”) for antidumping and countervailing duty (“AD/CVD”)...more

Hinshaw & Culbertson - Consumer Crossroads

New Law May Require Texas Homeowners to Renew Homestead Exemptions

Texas property taxes and the general residential homestead exemptions have been all over the news this past year due to the passing of Proposition 4 in November 2023. This law increased the annual Texas homestead tax...more

Fenwick & West LLP

Domestication with a Twist: A Tax Case Study

Fenwick & West LLP on

The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The problem with participation agreements

A 401(k) plan with multiple participating employers hosts several problems. The first is recognizing any control group or affiliated service group rules that treat such a plan for compliance purposes as a single plan or a...more

Husch Blackwell LLP

The Inflation Reduction Act’s Brownfields Adder: Updates on What Sites Qualify

Husch Blackwell LLP on

As detailed previously, the Inflation Reduction Act (IRA) offers incentives to renewable energy development that takes place on certain properties that are affected by potential or confirmed contamination. Under the IRA, a...more


Weekly Blockchain Blog - July 2024 #3

BakerHostetler on

Stablecoin Demand Increases with Initiatives Announced in Germany, Hong Kong - Recent reports highlight an increasing demand for stablecoins. According to one report, the market cap of the PYUSD stablecoin recently...more

Bricker Graydon LLP

Which Should You Choose: Health Savings Accounts vs. Health Reimbursement Accounts

Bricker Graydon LLP on

When it comes to pre-tax savings for qualifying medical expenses, employers have several options available to offer employees. Two of the more popular options are health savings accounts (HSAs) and health reimbursement...more

Hogan Lovells

Tax treatment of Carried Interest in Germany – Case law confirmed by Federal Tax Court

Hogan Lovells on

The highest German tax court confirmed again its position on the tax treatment of carried interest in a recent decision (docket number VIII R 3/21, decision dated 16 April 2024) published on 18 July 2024. For German income...more

Foster Swift Collins & Smith

Business Owners: How to Avoid Additional Estate Taxes after Connelly v. Commissioner

In early June, the Supreme Court issued an opinion that clarifies how company-owned life insurance impacts the value of the company for estate tax purposes. As a business owner, you may need to re-evaluate the use of those...more

Kohrman Jackson & Krantz LLP

Understanding the 2024 Property Reappraisal in Cuyahoga County

On July 9, 2024, the Cuyahoga County Fiscal Officer (the County) released the newly appraised values for properties within their jurisdiction. As required by state law, every county in Ohio is required to update property...more

Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

Proskauer - Tax Talks on

On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

Eversheds Sutherland (US) LLP

Swiss sign Model 1 IGA with United States and resolve transition issues

On June 27, 2024, Switzerland and the United States executed the Agreement between Switzerland and the United States of America to Improve International Tax Compliance and to Implement FATCA (New IGA), which will take effect...more

Seward & Kissel LLP

New FATCA Agreement with Switzerland

Seward & Kissel LLP on

The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more

Dechert LLP

Modernization of French Alternative Investment Funds: The Stakes of Ordinance No. 2024-662 Dated July 3, 2024

Dechert LLP on

The French Ordinance no. 2024-662 dated July 3, 2024, on the modernization of the regime governing alternative investment funds (the Ordinance) represents a major step forward. This has been long called in the Paris...more

Foley & Lardner LLP

Section 1446(f) Withholding and Private Fund Admissions and Withdrawals

Foley & Lardner LLP on

Withholding Under Code Sections 1446(a) and 1446(f) A partnership, such as a fund treated as a partnership for U.S. federal income tax purposes, that realizes income effectively connected with the conduct of a trade or...more

Holland & Knight LLP

U.S. Supreme Court Rulings Affect Challenges to Tax Regulations

Holland & Knight LLP on

Upon closing its October 2023 term, the U.S. Supreme Court issued two significant opinions – despite neither being a tax case – that will have broad consequences for taxpayers seeking to challenge tax regulations and other...more

Holland & Knight LLP

Finland Proposes Sweeping Reform of Gaming Market with Open Licensing System

Holland & Knight LLP on

The Finnish government has unveiled a draft law proposing a major overhaul of the country's gaming regulatory landscape. The proposed system, targeted for launch in January 2027, would usher in a new era of open competition...more

Nutter McClennen & Fish LLP

The Real Impact (Summer 2024)

Welcome to the inaugural edition of The Real Impact. In this edition, we discuss three strategic alternatives to consider for nonprofit integration and insights on the proposed regulations on donor advised funds. Guest author...more

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JD Supra Privacy Policy

Updated: Dec 28, 2021:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

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Collection of Information

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How We Protect Your Information

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Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

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You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
150 Harbor Drive, #2760
Sausalito, CA 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

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California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
150 Harbor Drive, #2760
Sausalito, CA 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

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Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

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JD Supra Cookie Guide

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How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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Controlling and Deleting Cookies

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Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

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