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DLA Piper

Energy Regulatory Update (UK) – November

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Our energy regulatory teams across Europe provide updates to clients on a regular basis. This newsletter contains a selection of recent UK news items of relevance to the energy transition and more generally to the energy and...more

McAfee & Taft

Trump accounts: The basics

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On December 2, 2025, the Department of the Treasury and the Internal Revenue Service issued a notice of proposed rulemaking regarding the new “Trump accounts,” which were created by the One Big Beautiful Bill Act. The...more

DLA Piper

IRS issues Notice 2025-75, Notice 2025-77, and Notice 2025-78

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On December 4, 2025, the United States Internal Revenue Service (IRS) published Notice 2025-75, Notice 2025-77, and Notice 2025-78 providing guidance on certain provisions that were modified as a result of the H.R. 1, P.L....more

Vorys, Sater, Seymour and Pease LLP

The Ohio SALT Chronicle - Issue 5

The nation recently slid past Black Friday and now is bounding through the busy holiday retail season. Retailers should be preparing for a unique challenge that awaits in the New Year....more

Allen Matkins

Equity Compensation and Profits Interest Incentive Structures in Companies

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With the end of the fiscal year approaching, we continue to see an uptick in the number of clients seeking counsel on structuring equity incentive plans. As our clients take a look back at the prior year’s performance and a...more

Groom Law Group, Chartered

A Big, Beautiful Break for HSAs: IRS Guidance on the One Big Beautiful Bill Act’s HSA Provisions

On December 9, 2025, the IRS issued Notice 2026-05, which provides guidance on the HSA provisions in the One Big Beautiful Bill Act (“OBBB”). The Notice provides much-anticipated guidance right before many of these provisions...more

Allen Barron, Inc.

IRS Continues to Tighten its Focus on U.S. Cryptocurrency Investors

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2025 has brought substantial new challenges as the IRS continues to tighten its focus on U.S. cryptocurrency investors. Cryptocurrency brokerages are required to report gross proceeds for each digital asset transaction they...more

DLA Piper

Tax in a Time of Transition: Navigating the Shifting Global Tax Policy Landscape

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The global tax environment is becoming increasingly complex and interconnected, with significant implications for compliance, risk management, and strategic planning. Recent developments such as the OECD’s Pillar Two...more

Tonkon Torp LLP

Oregon’s Property Tax Compression Problem Is Back in Spotlight

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Property tax compression is back in the news in Oregon because of a recent combination of a softening market, rising assessments, and local government funding stress. Understanding these shifts now is critical for property...more

DLA Piper

Trending in Transactions - Q4 2025

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Employee stock ownership plans - Navigating the fiduciary maze: The role of independent oversight in ESOP M&A transactions - Employee stock ownership plans (ESOPs) have gained traction in recent years, driven by...more

Cohen Seglias Pallas Greenhall & Furman PC

Surviving Spouse's Checklist

Losing a spouse is an overwhelming experience, and the practical tasks that follow can feel especially daunting. While every estate is different, having a clear roadmap of what to address and when can help you stay organized...more

WilmerHale

Favorable Stock Buyback Regulations May Entitle Some Taxpayers to Refunds

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On November 21, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) under Section 4501, which imposes a 1% excise tax on certain...more

Foley & Lardner LLP

Updates for Overtime and Tip Reporting Obligations for 2025

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As we wrote on July 14, 2025, the One Big Beautiful Bill Act (OBBA) contains a provision providing a tax deduction for employees’ overtime income in 2025 through 2028....more

Procopio, Cory, Hargreaves & Savitch LLP

GAO Report Signals Intensified IRS Scrutiny of Puerto Rico Act 60 Residents

The U.S. Internal Revenue Service (IRS) appears to be entering a new and far more aggressive phase of enforcement focused on taxpayers claiming Puerto Rico residency and Act 60 (formerly Act 22) incentives or benefits. The...more

DarrowEverett LLP

Navigating Complex Asset Valuation in High-Net-Worth Divorces

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In high-net-worth (“HNW”), what you own is rarely the real battle, it’s what those assets are truly worth. HNW divorces bring unique financial and legal challenges that go far beyond traditional marital estate division....more

PilieroMazza PLLC

Passport to Trouble: Court Dismisses Foreign Bank Accountholders’ Penalty Challenge

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Enforcing foreign bank account reporting requirements through penalties has been an IRS priority for several years, spawning numerous precedent-setting cases throughout the courts. In the latest such case[1], a federal...more

Bricker Graydon LLP

Year-end Tax Challenges for Benefits While on Leave

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We get questions on administering benefits for employees on approved leaves year-round. But with the new year approaching, it is important to understand the tax issues affected by your administration of group health plan...more

Royer Cooper Cohen Braunfeld LLC

5 Easy But Effective Year-End Tax Strategies That Can Meaningfully Cut Your 2025 Tax Bill

As 2025 comes to a close, business owners and other high-income individuals still have an opportunity to make strategic moves that can materially reduce their tax liability and improve cash flow....more

Mayer Brown

Application du taux de marché à un prêt intragroupe par voie de réclamation

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Le Conseil d’Etat rend une décision sur une demande d’application de la règle dite du « taux de marché » prévue à l’article 212, I-a du Code général des impôts a posteriori sur réclamation du contribuable. Contrairement à...more

Mayer Brown

Bénéficiaire effectif et non-application d’un taux réduit de retenue à la source en présence de dividendes versés à une société...

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Le Tribunal administratif de Paris valide la remise en cause par l’administration fiscale du taux réduit de retenue à la source de 5 % prévu par la convention franco-luxembourgeoise en présence de dividendes versés à une...more

McDermott Will & Schulte

Potential refund opportunity of buyback excise tax based on § 4501 final regulations

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Taxpayers who paid the stock repurchase excise tax based on prior guidance provided in Notice 2023-2 and the proposed regulations under Internal Revenue Code (IRC) § 4501 may be entitled to a refund based on changes made in...more

Bradley Arant Boult Cummings LLP

How Will the Cannabis World Look When Marijuana Is Rescheduled? (UPDATED)

A few weeks ago, someone at a holiday party asked “Whitt, why doesn’t Budding Trends take on the weighty legal issues of the day and instead resort to cheap pop culture references and puns?” I thought about responding with a...more

Benesch

Mission India Update Following Implementation of Online Presence Review – Widespread Rescheduling of H-1B and H-4 Visa...

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This alert provides an update to our client communication issued last week regarding the Department of State’s new Online Presence Review requirement for H-1B applicants and their dependents. Following that announcement,...more

McDermott Will & Schulte

Treasury issues transition guidance for taxpayers with one-month deferral elections

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The Internal Revenue Service (IRS) recently released Notice 2025-72 as a preview of forthcoming regulations addressing the repeal of the one-month deferral election under Section 898(c)(2) and modifications to the treatment...more

Baker Botts L.L.P.

California 2026 Billionaire Tax Act

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On October 22, 2025, a ballot initiative titled the “2026 Billionaire Tax Act” was filed with the California Attorney General. An amendment to the initiative was filed on November 26, 2025....more

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