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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
A&O Shearman

Contractual conundrum: variation or replacement?

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Have you amended a contract recently? The UK Supreme Court in Cobalt v HMRC has said that whether a contract has been varied, or replaced, depends on the parties’ common intention, objectively ascertained. So if you are...more

A&O Shearman

Pensions: what's new this week December 2, 2024

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Welcome to your weekly update from the A&O Shearman pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions. DB Funding code: Fast Track submission tests and conditions...more

Hogan Lovells

Summaries of the most significant Luxembourg draft laws in 2024

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The below summary deals with the most relevant Luxembourg corporate and individual tax measures proposed in 2024, which cover, among others, the decrease of the corporate income tax rate, the introduction of a subscription...more

Jackson Lewis P.C.

Potential Shifts in Employee Benefits: A Guide for Employers Under Trump

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As we prepare for another change in Administration in the White House, it is crucial for employers and plan sponsors to stay informed and prepared. While much of what lies ahead is speculative, understanding these possible...more

Rodemer Kane Attorneys at Law

Tax Fraud: Simple Mistake or Serious Crime?

Taxes. Except for maybe the CPAs and tax professionals, the word alone elicits groans and sighs from even the most cheerful among us. While the necessity of taxes is rarely disputed, navigating the complex world of tax...more

Kilpatrick

New Form Section 83(b) Election Released by IRS

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On November 7, 2024, the IRS released Form 15620, which can be used by taxpayers to file Section 83(b) elections in connection with transfers of property that are subject to a substantial risk of forfeiture when transferred...more

Saiber LLC

What Is Estate Administration and How Long Does It Last?

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When an individual passes away, their assets must be distributed to their named heirs or beneficiaries. The beneficiaries may be designated as a co-owner or a beneficiary, or the assets will pass to the estate to be...more

Foodman CPAs & Advisors

BOI Reporting Relief for Hurricane Victims

On 10/29/24, FinCEN announced Beneficial Ownership Information (BOI) Reporting Relief to specific victims of Hurricane Milton, Hurricane Helene, Hurricane Debby, Hurricane Beryl, and Hurricane Francine. BOI Reporting Relief...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations on the Advanced Manufacturing Production Credit Under Section 45X of the...

Under the final regulations, taxpayers are permitted to produce eligible components using recycled materials. Components which are sold and then later become defective will not be considered defective components for...more

King & Spalding

OIG Issues Nursing Facility Compliance Guidance

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On November 20, 2024, OIG released new compliance program guidelines for nursing facilities titled, “Nursing Facility Industry Segment-Specific Compliance Program Guidance” (the Nursing Facility ICPG or the Guidance). The...more

Gray Reed

Giving Season: Tax Edition

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With the holiday season officially upon us, the Dollars and Sense team wants to make sure you maximize your giving and gifting! For so many businesses, and business owners, this time of year also means employer festivities,...more

Orrick, Herrington & Sutcliffe LLP

Legal Ninja Snapshot: #ESOP & Flips - U.S. ESOPs for Employees of the German Subsidiary Now Available

Good news! The second chamber (Bundesrat) has now paved the way for the eagerly awaited and much-debated inclusion of a group privilege in sec. 19a of the German Income Tax Act (“EStG”). German start-ups that have done the...more

Groom Law Group, Chartered

IRS Releases New Form for 83(b) Elections  

Earlier this month, the IRS released Form 15620, a new standardized form for taxpayers seeking to make elections under Internal Revenue Code (“Code”) section 83(b). Previously, to make this election, taxpayers needed to...more

Mayer Brown

Angola Incremental Production Decree and Other Ongoing Developments

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On November 20, 2024, Angola enacted Presidential Decree 8/24 on Oil & Gas Incremental Production (“Incremental Production Decree”). This legal statute creates a new special legal and tax framework aimed to promote additional...more

Farrell Fritz, P.C.

International Tax Changes on the Horizon

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There are two recent taxpayer-friendly updates of note in the international tax filing arena. First, Internal Revenue Service (“IRS”) Commissioner Danny Werfel recently announced that the IRS is ending its automatic...more

Clark Hill PLC

2025 Economic Package: Key Changes in Tax Matters

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On Nov. 15, the Federal Executive Branch presented the Economic Package for 2025 (“EP 2025”) to Congress, which estimates around 294 billion United States Dollars (“USD”) in tax revenue. The EP is a set of proposals,...more

Dickinson Wright

Employer-Provided Gifts: Taxable or Not?

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As we approach the holiday season, many employers consider giving employees a gift as a token of appreciation. What employers may not consider is whether those gifts create taxable income to employees....more

Clark Hill PLC

Paquete Económico 2025: Principales Modificaciones en Materia Fiscal

Clark Hill PLC on

Nota: El 15 de noviembre de 2024, el Ejecutivo Federal presentó ante la Cámara de Diputados el Paquete Económico para el 2025 (“PE 2025”), mismo que contempla 5.3 billones de pesos en ingresos tributarios. El paquete...more

McDermott Will & Emery

Weekly IRS Roundup November 11 – November 15, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 11, 2024 – November 15, 2024. November 11, 2024: The IRS released Internal Revenue Bulletin...more

McDermott Will & Emery

Key Takeaways | Don’t Be Privileged When Asserting Privilege

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This session of the Private Client West Coast Forum 2024 identified common types of privilege, highlighting potential pitfalls to avoid and tools to protect a client’s privileged information. Types of privilege include...more

McDermott Will & Emery

Key Takeaways | Planning Ahead for Successful Post-Death Administration

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This session of the Private Client West Cost Forum 2024 discussed best avenues for family offices and their advisors to consider when managing a complex post-death administration, including steps to address and anticipate...more

McDermott Will & Emery

Key Takeaways | IRS & FTB: Ultra High-Net-Worth Targets, Taxes & Tips

McDermott Will & Emery on

This session of the Private Client West Cost Forum 2024 explored the current state of audits and tax controversy and shared practical advice to prepare for challenges ahead of a contest with the IRS or Franchise Tax Board...more

McDermott Will & Emery

Key Takeaways | Family Offices: Evolution & Efficiencies

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This session of the Private Client West Coast Forum 2024 focused on recent developments, including income tax planning to support investment performance, executive compensation planning, private placement life insurance...more

Benesch

Pick A State, But Not Just Any State: Key Considerations For Motor Carriers and Private Fleet Operators When Choosing Which State...

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Motor carriers and private fleet operators need to weigh several critical factors when deciding where to register and plate their motor vehicles and equipment (trailers, flatbeds, tanker units, etc.).  Selecting the right...more

Allen Barron, Inc.

What is Willful Blindness According to the IRS?

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What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more

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