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Mandelbaum Barrett PC

Challenge to New Jersey Partnership Filing Fee Rejected by Federal Court

Mandelbaum Barrett PC on

In a recent decision, the U.S. Court of Appeals for the 3rd Circuit upheld New Jersey’s partnership filing fee, rejecting a constitutional challenge brought forward by Energy Transfer L.P. (Energy Transfer L.P. v. Ficara, et...more

Arnall Golden Gregory LLP

How the Corporate Transparency Act Impacts Many Wealthy Families

In case you missed our firm’s previous newsletters, a new federal law imposed reporting requirements for many corporations, partnerships, and LLCs. The Corporate Transparency Act (“CTA”) requires companies and their owners to...more

Mayer Brown

Full Transaction Program Established to Reduce Federal Tax Litigation

Mayer Brown on

On August 30, 2024, Ordinance MF No. 1,383 was published, establishing the Full Transaction Program (PTI). The PTI provides a set of measures to reduce federal tax litigation with “high economic impact,” encouraging the...more

Eversheds Sutherland (US) LLP

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

McDermott Will & Emery

Weekly IRS Roundup August 26 – August 30, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26, 2024 – August 30, 2024. ...more

Bricker Graydon LLP

Nexus Pipeline Settlement Update

Bricker Graydon LLP on

The Nexus Pipeline (Nexus), which transports natural gas from eastern Ohio to Canada, was placed in-service in 2018. Nexus appealed its initial tax valuation in November 2019 and ultimately reached a settlement regarding tax...more

Baker Donelson

Business Income and Sales/Use Taxes: What Constitutes a Manufacturer for Certain Tax Incentives

Baker Donelson on

Manufacturing, as often noted, is the backbone of the American economy. Manufacturers not only innovate and create products that contribute to the betterment of our way of life but are also critically fundamental to our...more

Foodman CPAs & Advisors

Taxpayers Abroad are Underserved and Challenged

The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more

Brownstein Hyatt Farber Schreck

Brownstein Sponsors the 2024 Rockies Petroleum Conference

Brownstein was privileged to sponsor this year’s Rockies Petroleum Conference, hosted by the Petroleum Association of Wyoming, in Laramie, Wyoming, on Aug. 21–23, 2024....more

Dunlap Bennett & Ludwig PLLC

The Strategy Behind Spousal Lifetime Access Trusts (SLATS)

With continuing uncertainty regarding the federal estate tax laws, the Spousal Lifetime Access Trust (SLAT) is a popular option that helps high net-worth individuals maintain flexibility while maximizing their financial...more

Snell & Wilmer

Back By Popular Demand: IRS Temporarily Reopens Employee Retention Credit Voluntary Disclosure Program

Snell & Wilmer on

Earlier this year, the IRS launched a Voluntary Disclosure Program (VDP) under which taxpayers could return Employee Retention Credits (ERCs) received based on inaccurate or ineligible filings. The initial phase of the VDP...more

Proskauer Rose LLP

Wealth Management Update - September 2024

Proskauer Rose LLP on

The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September applicable federal rate (“AFR”) for use...more

Patterson Belknap Webb & Tyler LLP

Interim Guidance on Matching Qualified Student Loan Payments

Until recently, employer matching contributions under qualified plans were required to be conditioned solely upon employee contributions made to the plan. However, one of the many changes enacted by the Consolidated...more

Brooks Pierce

Planning for the Sunset of the Gift and Estate Tax Exemption

Brooks Pierce on

Today’s federal estate and gift tax laws may be remembered as the most generous to wealthy families since the Great Depression. The 2017 Tax Cuts and Jobs Act (TCJA) doubled the federal estate, gift, and generation skipping...more

Jackson Walker

Employee Retention Credit Worries?: IRS Voluntary Disclosure Program Reopened through November 22

Jackson Walker on

The IRS is offering a second chance for employers to give back funds received from improper Employee Retention Credit (“ERC”) claims. What’s more is that the IRS is offering a 15% discount on the amount to be returned, plus a...more

Warner Norcross + Judd

Attention Auto Suppliers: Don’t Leave Money on the Table Through Unused Retirement Forfeitures and Unallocated Accounts

We understand that running an automotive supplier business involves more than just industry-specific issues. That's why we regularly provide important insights and tips on broader legal trends to help you navigate challenges...more

Cozen O'Connor

Pennsylvania Commonwealth Court Decides Tax Exemption for Goodwill Industries

Cozen O'Connor on

In May 2020, Goodwill Industries of North Central Pennsylvania, Inc. (Goodwill) acquired the building in State College, Pennsylvania, in a high-traffic area that had numerous retail stores in the immediate vicinity. Later...more

Crunched Credit

How to Play An (Apparently) Manichean Election

Crunched Credit on

If it really didn’t matter, all this electioneering drama would be good fun, wouldn’t it?  Throw in some sex and a car chase and this would work on Netflix!  Regrettably, in the real world, it is less than entirely amiable....more

Conyers

Increased Enforcement Actions Regarding Cayman Islands Economic Substance

Conyers on

In 2024, there has been a sharp increase in the number of enforcement actions initiated by the Cayman Islands Tax Information Authority (“TIA”) and fines levied against relevant entities (such as Cayman Islands exempted...more

Eversheds Sutherland (US) LLP

Proposed regulations reduce flexibility of foreign currency mark-to-market election

On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more

Keating Muething & Klekamp PLL

QSBS Tax-Deferred Rollover

Today, many business owners are aware of qualified small business stock (“QSBS”) and the exclusion from gain on certain sales of QSBS under §1202, but it is still common to encounter business owners who are either unaware of...more

A&O Shearman

New draft of Polish markets in crypto-assets act – evolution or revolution in the legislative process?

A&O Shearman on

Although the Regulation of the European Parliament and of the Council (EU) 2023/1114 of 31 May 2023 on crypto-assets markets (the MiCAR) was published in June 2023, the work on laws implementing it in Poland is still in...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – August 23, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19, 2024 – August 23, 2024. August 19, 2024: The IRS released Internal Revenue Bulletin...more

Eversheds Sutherland (US) LLP

Short tax year savior: Rev. Proc. 2024-34

Welcome relief to taxpayers with short tax years seeking to file Section 174 accounting method changes - On August 29, 2024, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc....more

Seyfarth Shaw LLP

Major SECURE 2.0 Guidance Issued: Extra Credit for Repaying Qualified Student Loans

Seyfarth Shaw LLP on

Seyfarth Synopsis: On August 19, 2024, the IRS issued Notice 2024-63 (the “Notice”) providing guidance for plan sponsors that wish to provide matching contributions based on eligible student loan repayments made by...more

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