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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

Proskauer - Tax Talks on

On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

Eversheds Sutherland (US) LLP

Swiss sign Model 1 IGA with United States and resolve transition issues

On June 27, 2024, Switzerland and the United States executed the Agreement between Switzerland and the United States of America to Improve International Tax Compliance and to Implement FATCA (New IGA), which will take effect...more

Seward & Kissel LLP

New FATCA Agreement with Switzerland

Seward & Kissel LLP on

The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more

Dechert LLP

Modernization of French Alternative Investment Funds: The Stakes of Ordinance No. 2024-662 Dated July 3, 2024

Dechert LLP on

The French Ordinance no. 2024-662 dated July 3, 2024, on the modernization of the regime governing alternative investment funds (the Ordinance) represents a major step forward. This has been long called in the Paris...more

Foley & Lardner LLP

Section 1446(f) Withholding and Private Fund Admissions and Withdrawals

Foley & Lardner LLP on

Withholding Under Code Sections 1446(a) and 1446(f) A partnership, such as a fund treated as a partnership for U.S. federal income tax purposes, that realizes income effectively connected with the conduct of a trade or...more

Holland & Knight LLP

U.S. Supreme Court Rulings Affect Challenges to Tax Regulations

Holland & Knight LLP on

Upon closing its October 2023 term, the U.S. Supreme Court issued two significant opinions – despite neither being a tax case – that will have broad consequences for taxpayers seeking to challenge tax regulations and other...more

Holland & Knight LLP

Finland Proposes Sweeping Reform of Gaming Market with Open Licensing System

Holland & Knight LLP on

The Finnish government has unveiled a draft law proposing a major overhaul of the country's gaming regulatory landscape. The proposed system, targeted for launch in January 2027, would usher in a new era of open competition...more

Nutter McClennen & Fish LLP

The Real Impact (Summer 2024)

Welcome to the inaugural edition of The Real Impact. In this edition, we discuss three strategic alternatives to consider for nonprofit integration and insights on the proposed regulations on donor advised funds. Guest author...more

Blank Rome LLP

Potential State and Local Tax Implications of the U.S. Supreme Court’s Decision in Loper Bright Enterprises v. Raimondo

Blank Rome LLP on

On June 28, 2024, the U.S. Supreme Court issued its decision in Loper Bright Enterprises et. al. v. Raimondo, Secretary of Commerce, et. al., No. 22-451 603 U.S. ___, (June 28, 2024), in which it held that in interpreting...more

Blank Rome LLP

To Be or Not To Be A Unitary Business

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Oftentimes companies are on the defense in establishing that they are not operating a unitary business to avoid excessive taxation by a State. Yet, there are occasions when companies take the offense—and are successful. In...more

Blank Rome LLP

New Mexico Again Loses Unity of Foreign Income

Blank Rome LLP on

The New Mexico Taxation & Revenue Department (“Department”) wrongly ignored the statutory exclusion for foreign corporations incorporated in foreign countries that do not engage in a trade or business in the United States...more

Locke Lord LLP

UPDATE – Form 5330 E-Filing Requirement Headache Relieved for 2024

Locke Lord LLP on

In a blog post dated May 10, 2024, we discussed the Form 5330, an excise tax return used by certain employers and individuals to pay penalty taxes with respect to employee benefit plans, must be filed electronically for...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update - July 2024

Holland & Hart LLP on

Welcome to the buzz, our monthly cannabis news and policy update. Your at-a-glance source for regulatory developments, agency announcements, and trends impacting the cannabis industry. - This month's highlights include: ...more

McGlinchey Stafford

TIGTA Reports: Virtual Currency Tax Compliance Enforcement Can Be Improved

McGlinchey Stafford on

The number of virtual currency types has added to this problem. According to TIGTA, the number of virtual currencies has grown significantly since April 2020, from 5,000 to over 26,000 (420 percent) as of July 2023. The two...more

Foodman CPAs & Advisors

AML/CFT FinCEN Proposed Rule

On 6/29/24, FinCEN, in consultation with the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union...more

Allen Barron, Inc.

US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen

Allen Barron, Inc. on

In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more

Blank Rome LLP

South Carolina Supreme Court Declares Facially Discriminatory Sales Tax Exemption Invalid

Blank Rome LLP on

It is well settled that states may not discriminate against interstate commerce in the name of intrastate economic development. Recently, in the consolidated cases Orthofix, Inc. v. Dep’t of Rev., App. No. 2023-000317 (S.C....more

Morgan Lewis

DC’s False Claims Act Enforcement Boosted By $40 Million Tax-Related Settlement

Morgan Lewis on

To generate revenue, increase enforcement resources, and “crack down on tax fraudsters,” the District of Columbia amended its False Claims Act (DC FCA) in 2021 to expressly impose liability arising from DC tax code...more

Troutman Pepper

State Licensing Considerations for Tobacco and Nicotine Product Manufacturers, Importers, Distributors, and Retailers

Troutman Pepper on

In this post, we take a closer look at state tobacco and nicotine product licensing considerations. When approaching state licensing issues, it may be helpful to establish a checklist to help manufacturers, importers,...more

Pullman & Comley - Labor, Employment and...

Reminder: July 31 Is the PCORI Fee Remittance Deadline for Self-Insured Health Plans

Employers that sponsor a self-insured health plans must submit their Patient-Centered Outcomes Research Institute (PCORI) fees to the Internal Revenue Service by July 31, 2024. Plan sponsors need to calculate their PCORI fee...more

Foodman CPAs & Advisors

RFI De IA Emitido Por El Tesoro De EE. UU.

El 6/6/24, el Tesoro de los Estados Unidos emitió una Solicitud de Información (“RFI – Request for Information”) para los usos, oportunidades y riesgos de la Inteligencia Artificial (IA) en el Sector de Servicios Financieros....more

Foodman CPAs & Advisors

AI RFI Issued By U.S. Treasury

On 6/6/24, the U.S. Treasury issued a Request for Information (RFI) for the uses, opportunities, and risks of Artificial Intelligence (AI) in the Financial Services Sector. The AI RFI presents nineteen questions that are...more

McDermott Will & Emery

Weekly IRS Roundup July 8 – July 12, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 8, 2024 – July 12, 2024. ...more

Eversheds Sutherland (US) LLP

Treasury and the IRS issue final regulations addressing the payment and reporting of the stock buyback tax

On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more

Mayer Brown

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

Mayer Brown on

In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more

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JD Supra Privacy Policy

Updated: Dec 28, 2021:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

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How We Protect Your Information

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Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

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You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
150 Harbor Drive, #2760
Sausalito, CA 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

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California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
150 Harbor Drive, #2760
Sausalito, CA 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

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JD Supra Cookie Guide

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How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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There are different types of cookies and other technologies used our Website, notably:

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JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

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Controlling and Deleting Cookies

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Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

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