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Goodwin

August 2024 German Court Ruling Reshapes Tax Strategy for Luxembourg Funds

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On August 22, 2024, Germany’s Federal Fiscal Court (Bundesfinanzhof) published a decision that refocuses attention on the complexities of cross-border taxation, particularly for Luxembourg-based funds investing in Germany....more

Proskauer - Tax Talks

California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules – Implications for Asset Managers

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On September 13, 2024, California’s Franchise Tax Board (“FTB”) released updated proposed regulations (“Draft Regulations”), which would amend the rules regarding market-based sourcing for sales other than sales of tangible...more

Eversheds Sutherland (US) LLP

Be careful what you wish for: IRS and Treasury release goliath CAMT NPRM full of nuance and complexity

On September 12, 2024, the Internal Revenue Service and Department of the Treasury (collectively, the Government) issued long-awaited proposed regulations (the NPRM), providing guidance regarding application of the corporate...more

Smith Anderson

Franchise Tax Refund Opportunity

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Corporations subject to North Carolina’s franchise tax have an opportunity to seek refunds of their 2021 and 2022 franchise taxes but should act promptly to preserve their rights....more

Walkers

Pillar Two - Global Minimum Taxation and Ireland

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The Irish Pillar Two rules apply to in-scope entities for accounting periods commencing on or after 31 December 2023. Following the GloBE Rules and the EU's Minimum Tax Directive, the rules introduce a minimum effective tax...more

Pullman & Comley - Labor, Employment and...

The Newest Wage Hour Risk in Connecticut: Election Poll Workers

A new Connecticut law went into effect this year creating early voting procedures for the first time in Connecticut.  The law, Connecticut General Statutes § 9-163aa, provides that before each election, a period of early...more

Holland & Knight LLP

Treasury, IRS Release Proposed Regulations Under Section 30C

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The U.S. Department of the Treasury and IRS on Sept. 18, 2024, released proposed regulations under Section 30C of the Internal Revenue Code regarding the Alternative Fuel Vehicle Refueling Property Credit. The proposed...more

Pierce Atwood LLP

New Guidance for Clean Electricity Low-Income Communities Bonus Program

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The U.S. Department of the Treasury recently issued proposed regulations to implement the Clean Electricity Low-Income Communities Bonus Program, which was created under the Inflation Reduction Act to incentivize clean energy...more

Fleurinord Law PLLC

Lessons from the Hunter Biden Tax Evasion Scandal

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Would you risk prison time to avoid paying taxes? That’s a question Robert Hunter Biden, publicly known as "Hunter Biden," may have asked himself when he faced serious tax evasion charges recently. While the case...more

Sheppard Mullin Richter & Hampton LLP

Lights, Camera, Tax Breaks: California’s Updated Film Incentives

In a state where the sun always shines, California’s film tax credits seem to be the script for success. On July 10, 2023, Governor Newsom signed legislation to extend and expand California’s $330 million-a-year Film and TV...more

Cozen O'Connor

Drafting Partnership Agreements: Ensuring You Get the Returns You Bargained For

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PIP (partners' interests in the partnership) allocations are very commonly used in partnership agreements. For this reason, Investors and managers should understand the basics of PIP allocations and whether and when they...more

Vinson & Elkins LLP

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

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On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Preliminary Data/IRA Energy Efficient Home Improvement Credits: Congressional Research Service Report

The Congressional Research Service (“CRS”) issued a September 16th report titled: Preliminary Data on the IRA Energy Efficient Home Improvement Credit (“Report”). CRS serves as shared staff to Congressional Committees...more

McDermott Will & Emery

Weekly IRS Roundup September 9 – September 13, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9, 2024 – September 13, 2024....more

Proskauer - Tax Talks

The IRS and Senator Warren Raise Concerns about Lodging and Health Care REITs

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On September 3, 2024, Senator Elizabeth Warren (D-MA) sent a letter to the Internal Revenue Service (the “IRS”) urging it to “increase enforcement scrutiny of REITs, especially large health and hospitality REITs that may be...more

Husch Blackwell LLP

Planning for Retirement Benefits Post-Secure Act

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On July 18, 2024, the Internal Revenue Service (IRS) issued final regulations updating the required minimum distribution (RMD) rules. The final regulations reflect changes made by the Setting Every Community Up for Retirement...more

IR Global

HMRC launches VAT registration tool

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A new digital VAT registration tool has been launched by HMRC that can be used to help businesses work out the effects of registering for VAT. The launch of the tool known as the VAT Registration Estimator came about...more

Conyers

Ten Things You Need To Know About… BVI Economic Substance

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The British Virgin Islands (the BVI), along with most other major offshore jurisdictions, has introduced “economic substance” requirements for entities carrying on certain specified activities. This economic substance regime...more

Katten Muchin Rosenman LLP

UK Financial Insights from Katten | Issue 14

UK Financial Insights from Katten is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds in the UK and Europe....more

Allen Barron, Inc.

What are Fractional CFO Services?

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What are fractional CFO services? What types of organizations should consider fractional CFO services for their corporation or business? What are the advantages of contracting for fractional Chief Financial Officer services?...more

ASKramer Law

Energy Tax Credits for a New World Part VII: Low-Income Communities Bonus Credits

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What is the Low-Income Communities Bonus Credit? The Low-Income Communities Bonus Credit available through the Inflation Reduction Act of 2022 (IRA) is designed to increase the siting of, and access to renewable energy...more

Holland & Knight LLP

Tribal GWE Proposed Regulations Are an Overdue Win for Indian Country

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The U.S. Department of the Treasury and IRS on Sept. 17, 2024, issued Proposed Regulations on the Tribal General Welfare Exclusion Act of 2014 (the Act). The Proposed Regulations are an overdue win for Indian country,...more

Schwabe, Williamson & Wyatt PC

Planning a Transaction in an Election Year? Stay The Course and Get Prepared

After slow deal flow last year, 2024 was expected to bring a resurgence in mergers and acquisitions as inflation eased and financing improved. In the first half of this year, transactions in the U.S. increased 6% over the...more

Jones Day

Taxing Tangle: U.S. IRS Releases Guidance for Clean Hydrogen Production Tax Credit

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The U.S. Internal Revenue Service ("IRS") has released proposed regulations regarding the Clean Hydrogen Production Tax Credit introduced in the Inflation Reduction Act of 2022 ("IRA"). The proposed regulations provide more...more

Conyers

Captive Insurance in Bermuda

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Bermuda is the world’s leading domicile for captive insurance companies, with over 600 active captive licences on its register generating over US$24 billion in gross written premium. Having formed the first modern captive in...more

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