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Burr & Forman

Tax-Exempt NIL Collectives Warned of “Smarter Enforcement” by IRS in 2025

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The Tax Exempt & Government Entities Division (TE/GE) of the Internal Revenue Service (IRS) recently published a program letter outlining the Division’s priorities in fiscal year 2025. The Division lists “tax-exempt...more

Ruder Ware

Ding Dong, the CTA is DEAD!

Ruder Ware on

A federal district court in Texas has issued a landmark decision postponing the enforcement of the Corporate Transparency Act (the “CTA”). The Court held that the CTA exceeds Congress’ power and is therefore likely...more

Polsinelli

Disregarded Entity Eligibility for the CTA Large Operating Company Exemption

Polsinelli on

As discussed in detail below, the Corporate Transparency Act (CTA) provides an exemption to its reporting requirements for certain large operating companies (the Large Operating Company Exemption or “LOC Exemption”). In order...more

Littler

Dear Littler: What are the tax implications of office gift-giving and donation matching?

Littler on

Dear Littler, We’d like to provide gifts to our staff for the holidays but are unsure which types of gifts would trigger tax obligations for our employees. We’d also like to offer donation matching for our employees’...more

Stinson LLP

1099-K Reporting: More Time to Transition to the $600 Reporting Threshold

Stinson LLP on

In the American Rescue Plan Act of 2021, Congress and the Biden administration lowered the minimum reporting threshold for filing information returns relating to “reportable payment transactions” (a payment card is accepted...more

Snell & Wilmer

2024 End-of-Year Plan Sponsor “To Do” List (Part 3) Qualified Retirement Plans

Snell & Wilmer on

As 2024 comes to an end, we are pleased to present our traditional End-of-Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate SW Benefits Updates. Part 1 addressed health and welfare plan...more

A&O Shearman

Treasury and the IRS proposed regulations on previously taxed earnings and profits

A&O Shearman on

On November 29, 2024, the U.S. Treasury Department and IRS released long-awaited proposed regulations (REG-105479-18) under sections 959 and 961, and certain other provisions of the Internal Revenue Code of 1986, as amended...more

IR Global

Autumn Budget 2024 – Inheritance Tax changes

IR Global on

A number of changes to Inheritance Tax (IHT) were announced as part of the Budget measures. We have covered each of the main measures below. It should be noted that these changes are not coming into effect until April 2026 at...more

Pierce Atwood LLP

Maine to Impose Sales and Use Tax on Leases; Limited Refunds Available

Pierce Atwood LLP on

Unlike most states, Maine taxes lessors on their purchase of tangible personal property for lease or rental, but generally does not tax lease and rental payments. Starting January 1, 2025, however, Maine will join the vast...more

King & Spalding

Senators Grassley and Warren Urge IRS to Increase Nonprofit Hospital Oversight Again

King & Spalding on

On November 19, 2024, a bipartisan pair of senators, Sen. Charles E. Grassley (R-Id.) and Sen. Elizabeth Warren (D-Ma.) united again, a year after a similar letter, to urge the Internal Revenue Service (IRS) to increase...more

Kilpatrick

A Recipe for Bad Tax Policy: False Claims Acts and Class Action Lawsuits in the World of State Taxation

Kilpatrick on

Perfection is often an admirable goal, but rarely achieved. However, in the current environment, failure to collect, report and remit your taxes perfectly, particularly in the sales and use tax arena, can leave a taxpayer...more

Jackson Lewis P.C.

Breaking Up: Why U.S. Citizens Living Abroad Renounce Citizenship

Jackson Lewis P.C. on

Approximately nine million U.S. citizens live or work abroad, and some want to renounce their U.S. citizenship. Many do so with regret but renounce to avoid various financial issues. Others consider themselves “accidental...more

Freeman Law

How to Compute the Texas Franchise Tax | Step 3 – Determining the Applicable Tax Rate

Freeman Law on

I’ve posted two blogs that cover the first two steps in computing the Texas Franchise Tax – the computation of “taxable margin” and the computation of the appropriate “apportionment factor.” Those posts can be found here and...more

McDermott Will & Emery

Update zum US-Transparenzregister

McDermott Will & Emery on

Handlungsbedarf für Unternehmen bis Jahresende - Nachdem das Transparenzregister in Deutschland und Europa inzwischen seit einigen Jahren existiert und dessen Meldepflichten in der Praxis umfassend beachtet werden, gibt...more

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

ArentFox Schiff on

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

Bowditch & Dewey on

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

A&O Shearman on

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

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