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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
K&L Gates LLP

The Inside Basis: Possible Estate Tax Rollback in the United States

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In our inaugural episode of The Inside Basis, Randy Clark is joined by Sarah Bowman, one of our estate planning and trust administration lawyers, and Lauren Anderson, a wealth advisor at J.P. Morgan Private Bank, to discuss...more

Eversheds Sutherland (US) LLP

Recent administrative guidance hints at tax accounting priorities heading into 2025

IRS LB&I has updated several pieces of administrative guidance, including a notice regarding the transition period for complying with increased substantiation requirements for research credit refund claims and two practice...more

McDermott Will & Emery

Exit tax for investement shares

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Anyone who moves out of Germany and has investment shares or transfers them outside of Germany will have to pay taxes – even if the shares are not sold. Private investors in investment funds will have to pay taxes in the...more

Conyers

Cayman Entities and the Economic Substance Regime – Is Your Cayman Entity in Compliance?

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As we gear up for the final quarter of 2024, this is an excellent time to review Cayman based entities with a financial year end of 31 December 2024 and consider the position of these entities with respect to the Cayman...more

Greenberg Glusker LLP

Related-Party Section 1031 Exchanges

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As the adage goes, “Don’t do business with relatives.” If a taxpayer enters into a Section 1031 tax-deferred real property exchange (an “Exchange”) with a relative or with a “related person” the adage can prove costly. ...more

Blake, Cassels & Graydon LLP

Canadian Registered Pension Plans Impacted by Recently Amended Income Tax Regulations

Regulations Amending the Income Tax Regulations (Technical Amendments) (Regulations) were published in the Canada Gazette, Part II on December 4, 2024. Draft versions of the Regulations had previously been released on August...more

J.S. Held

How to Defend Against Identity Theft This Tax Season

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In recent years, identity theft cases have surged, especially during tax season. According to the Internal Revenue Service (IRS), in 2022, the federal agency identified and prevented USD 5.7 billion in tax-related fraud, and...more

Faegre Drinker Biddle & Reath LLP

Things I Worry About (4): Automatic Enrollment (4)

SECURE 2.0 was enacted on December 29, 2022. Among its provisions is a requirement that “new” 401(k) plans and private sector 403(b) plans must automatically enroll their eligible employees, but not until the first plan year...more

Seyfarth Shaw LLP

Year-End Estate Planning for 2024

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A record-breaking stock market has again generated significant wealth this year. The gift tax, estate tax and generation-skipping transfer tax are all imposed on the fair market value of assets at the time of transfer. Gifts...more

Goodwin

A New Form Section 83(b) Election: IRS Form 15620

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As part of US tax planning for founders, employees, board members, and other individual service providers who receive equity that is subject to vesting in connection with their services, Section 83(b) elections are frequently...more

Adler Pollock & Sheehan P.C.

Loan or Gift? Handle Intrafamily Transfers with Care

If you’re like most people, an important goal of estate planning is to provide financial assistance to your children or other loved ones, ideally at the lowest possible tax cost. There are many strategies for achieving this...more

Cozen O'Connor

Cozen Cities - December 4, 2024

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CHICAGO — Teachers Union Narrows Contract Demands- After eight months of increasingly tense contract negotiations, the Chicago Teachers Union has now narrowed its number of demands to land a deal in the next month, the...more

Davies Ward Phillips & Vineberg LLP

Federal Court of Appeal Confirms CRA Can Collect Arrears Interest Despite Absence of a Tax Debt

The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments...more

Warner Norcross + Judd

Will Your Estate Distribution Mechanisms Actually Work Following an Unanticipated Incapacity or Death? Stress Testing Your Estate...

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The best way to be sure that your thoughtful estate planning will work as anticipated when the time comes is to walk through it with your planning attorney, from the viewpoint of a person beginning the task of administrating...more

Blake, Cassels & Graydon LLP

A Happy GST/HST Holiday for All Those Who Celebrate

The federal government has created a new “GST holiday” this season. Through Bill C-78, the Tax Break for All Canadians Act, the federal government plans to enact, for the first time, a temporary goods and services tax and...more

Bergeson & Campbell, P.C.

Petitions Filed to Add Several Chemicals to List of Taxable Substances; Comments Due January 28, 2025

On November 29, 2024, the Internal Revenue Service (IRS) announced that petitions have been filed to add the following chemicals to the list of taxable substances...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

IRS has a tough time with the 5500 “zig zag”

The Internal Revenue Service (IRS) doesn’t read the 5500s, but the Department of Labor (DOL) does....more

Winthrop & Weinstine, P.A.

Legislative Update: $616 Million Budget Surplus Projected

Minnesota Management and Budget (MMB) issued the November Budget and Economic Forecast this morning and has projected that the State of Minnesota will have a $616 million surplus for the upcoming FY 2026-2027 biennium...more

Groom Law Group, Chartered

2024 IRS PCORI Fee Increase

On December 2, the IRS issued Notice 2024-83, which increased the PCORI fee from $3.22 per covered life to $3.47 per covered life for policy and plan years that end on or after October 1, 2024 and before October 1, 2025....more

Walkers

Guernsey Protected Cell Companies (PCCs) - the key features

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Guernsey was the first jurisdiction to implement the protected cell company ("PCC"), doing so over 25 years ago. The PCC was originally created for use in insurance structures, although today it is also widely used for...more

Walkers

Advantages of Jersey and Guernsey companies as UK Qualified Asset Holding Companies (QAHCs)

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On 1 April 2022, the UK introduced a new tax advantaged corporate structure, a "qualifying asset holding company" ("QAHC"), which benefits from a number of UK tax breaks. A crucial requirement for QAHC eligibility is that...more

Walkers

Guernsey Adopts OECD's Global Minimum Tax Rate of 15%

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Guernsey has passed legislation to implement the OECD's global minimum tax rate of 15%, known as "Pillar 2", which will apply for fiscal years commencing on or after 1 January 2025....more

Walkers

Acquisition and Leveraged Finance in the Channel Islands

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Jersey and Guernsey (collectively, the "Channel Islands") remain popular for both private equity buyout structures of UK and international corporate groups across various industries and asset classes, and for leverage...more

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!

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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

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