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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

Goodwin on

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

Cozen O'Connor on

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

Walkers on

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)

Walkers on

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%

Walkers on

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

Walkers on

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!

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

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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

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