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Freeman Law

Tax Policy Expectations Under The Trump Administration

Freeman Law on

Former President Donald J. Trump won the 47th presidential election and his second term in the Oval Office on November 5, 2024. A change in administration almost always brings with it changes in policies. Below is a summary...more

ArentFox Schiff

A Tale of Two Recent QTIP Trust Termination Cases — Anenberg and McDougall

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Through the years, the US Tax Court has provided significant clarification on the gift tax consequences of terminating qualified terminable interest property (QTIP) trusts. Two new cases in 2024, Estate of Sally J. Anenberg...more

Orrick, Herrington & Sutcliffe LLP

Italy Founders Series - Stock Option Plans

Startups often cannot pay the high salaries of larger companies. By offering stock options, however, they can build competitive compensation packages that align employee and shareholder interests. To help startups and small...more

Cole Schotz

Death, Taxes and Shareholder Agreements: Lessons from the Connelly Case

Cole Schotz on

Recently, the U.S. Supreme Court ruled unanimously in Connelly v. United States, that the valuation of a decedent’s shares in a closely held corporation for federal estate tax purposes must include insurance proceeds received...more

Foodman CPAs & Advisors

Forms 3520 and 3520-A Late Filing get IRS Relief

On 10/24/24, the National Taxpayer Advocate shared on its NTA Blog that the IRS has discontinued its policy of automatically imposing penalties for late submissions of Form 3520, which pertains to foreign gifts and...more

Morris, Manning & Martin, LLP

IRS Issues New Form 15620 for Section 83(b) Elections

Many people make Section 83(b) elections, named for the subsection of the Internal Revenue Code of 1986 that authorizes them. Simply put, a Section 83(b) election allows taxpayers to include in their gross income the fair...more

Eversheds Sutherland (US) LLP

IRS provides additional transition relief for third party settlement organizations reporting on Form 1099-K

On November 26, 2024, the IRS issued Notice 2024-85, providing a revised timeline for the transition to the $600 threshold in section 6050W(e), as amended by the American Rescue Plan Act of 2021, for third-party settlement...more

Bowditch & Dewey

2024 Year-End Charitable Giving and IRA Qualified Charitable Distributions

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As the 2024 tax year comes to a close, owners of individual retirement accounts (IRAs) might consider combining the tax benefits of charitable giving with a qualified charitable distribution (QCD) from their IRA....more

Foster Garvey PC

What Is Likely the Last Chapter in the Wild Journey of the Washington State Capital Gains Tax Occurred on November 5, 2024, With...

Foster Garvey PC on

The Wild Journey - I am taking time out from my multi-part series on Subchapter S to report on the Washington capital gains tax. As you know, I have reported in several prior blog posts on the numerous challenges...more

A&O Shearman

Key takeaways from the Joint Ventures and Pillar Two in Practice webinar

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We recently hosted a webinar on Pillar Two and its practical impact on joint ventures (JVs). Our key takeaways are set out below. Introduction to Pillar Two - Pillar Two, also known as the global minimum tax, is an...more

Jones Day

Final Regulations Expand Access to "Direct Pay" Elections for Energy Credits

Jones Day on

The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations allowing tax-exempt entities that are partners in clean energy projects to elect to receive energy tax credits in cash....more

Bracewell LLP

Treasury and IRS Issue Final and Proposed Regulations Expanding Applicable Entities’ Ability to Elect Direct Pay in Connection...

Bracewell LLP on

On November 19, 2024, the Treasury Department and the Internal Revenue Service issued final regulations under Internal Revenue Code (Code) Section 761 (the Final Regulations) enabling certain entities to make a direct pay...more

Stark & Stark

Navigating Gift Treatment in Divorce: Key Considerations

Stark & Stark on

The end of the year is upon us, and often parents or other individuals make gifts to their children for the maximum amount allowable to avoid federal and state gift taxes. In the absence of marital bliss, how these gifts are...more

Miller Canfield

The Gift and Estate Tax Exclusion: Lock It In or Let it Ride?

Miller Canfield on

The Gift and Estate Tax Exclusion is currently scheduled to be reduced by approximately 50% in about 13 months. Without action from Congress, on January 1, 2026, the Exclusion will go from almost $14 million to about $7...more

Cozen O'Connor

Pennsylvania Enacts Significant Changes to Tax Appeal Processes

Cozen O'Connor on

Pennsylvania altered its tax appeal process at its two administrative boards — the Board of Appeals (BOA) and the Board of Finance and Revenue (BF&R) — to make changes favorable to taxpayers. Act No. 123, S.B. 1051, Oct. 29,...more

Ballard Spahr LLP

New IRS Form 15620 Standardization Simplifies Section 83(b) Elections

Ballard Spahr LLP on

The Internal Revenue Service (IRS) recently released IRS Form 15620, Section 83(b) Election (Form 15620), an approved form for taxpayers to use to make a Section 83(b) election. A taxpayer is not required to use Form 15620 to...more

Proskauer Rose LLP

UK Tax Round Up - November 2024

Proskauer Rose LLP on

Welcome to the November 2024 edition of our UK Tax Round Up. This month has seen publication of the Finance Bill 2024-25 and interesting cases on the loan relationship unallowable purpose test and the extent that tax applies...more

White and Williams LLP

The 12 Days of Year-End Estate Planning

White and Williams LLP on

As the end of 2024 draws near, it’s a great time to review your finances and prepare for a prosperous new year. Whether you’re cozying up by the fire or decorating with family, a little year-end financial planning can help...more

King & Spalding

November Employment Law Alert: A Hair-Raising Harassment Case, and Other Updates

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November saw several significant developments in employment law through the courts and following the Labour Government’s Autumn Budget, announced on 30 October 2024....more

McDermott Will & Emery

Weekly IRS Roundup November 18 – November 22, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18, 2024 – November 22, 2024. ...more

Buckingham, Doolittle & Burroughs, LLC

Challenges Businesses Face with Ohio State and Local Taxes

From understanding how businesses are taxed to navigating changes in Ohio tax regulations, it’s important to be aware of potential tax hurdles and how to proactively avoid them. This article from Buckingham, Doolittle &...more

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

A&O Shearman on

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

Hogan Lovells on

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

Jackson Lewis P.C. on

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

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