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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
Alston & Bird

IRS’s Advance Pricing and Mutual Agreement Program Rebounds in 2023: What Is APMA’s Long Game?

Alston & Bird on

APMA set a record for executed advance pricing agreements (APAs), but high processing times and a hefty pending APA inventory continued to challenge APMA in 2023. Our Federal & International Tax Group evaluates trends gleaned...more

ASKramer Law

Business Taxation of Hedging Transactions Part III: Identification Requirements and Aggregate Hedging

ASKramer Law on

When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more

Blank Rome LLP

South Carolina Legislature Severely Limits Department’s Ability to Force Companies to File Combined Returns

Blank Rome LLP on

Since the South Carolina Supreme Court held in Media General Communications, Inc. v. South Carolina Department of Revenue, 694 S.E.2d 525 (S.C. 2010), that the Department of Revenue (“Department”) had the authority to allow...more

Blank Rome LLP

Ohio Supreme Court Finds Federal Due Process Limitations Do Not Apply to Intrastate Taxation

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During the COVID-19 pandemic, many states enacted legislation trying to minimize the negative impact that the pandemic was having on state and local government budgets. It is in the context of the unprecedented circumstances...more

Allen Barron, Inc.

The Sunset of the TCJA – Tax Cuts and Jobs Act of 2017 – Is Scheduled for the End of 2025

Allen Barron, Inc. on

The sunset of the TCJA – the Tax Cuts and Jobs Act of 2017, is currently scheduled for the end of 2025.  The TCJA contributed substantial changes to the US tax code that have benefited many US taxpayers.  How should a US...more

Blank Rome LLP

What’s Shaking: Blank Rome State + Local Tax Roundup - April 2024

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Blank Rome’s nationally prominent State + Local Tax attorneys are thought leaders in the community as frequent guest speakers at various local and national conferences throughout the year. Our State + Local Tax attorneys...more

Blake, Cassels & Graydon LLP

Vente d’une entreprise de distribution d’assurances : mettre toutes les chances de son côté

Le marché fragmenté de la distribution d’assurances au Canada continue de faire l’objet d’un grand volume d’activités de fusion et acquisition (« F&A ») alors que les consolidateurs établis regroupent de petits courtiers...more

Blank Rome LLP

Misapplication of Complete Auto

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The South Dakota Supreme Court recently analyzed the four-part Complete Auto test to determine if the State’s use tax results in a burden on interstate taxation in Ellingson Drainage, Inc. v. South Dakota Department of...more

Newburn Law

Agricultural Estate Planning: Securing Your Land's Future

Newburn Law on

In the world of farming and ranching, ensuring your land's future is vital. That's where agricultural estate planning comes in. It's all about smoothly transitioning your farm or ranch to the next generation, maintaining its...more

Clark Hill PLC

[Webinar] Preparing for Clean Energy Tax Credit Transfer Transactions - May 1st, 12:00 pm - 1:00 pm EDT

Clark Hill PLC on

Project developers in the EV, solar, wind, battery, CCUS, hydrogen, biofuels, and energy efficiency markets have been blessed by the IRS with the ability to transfer tax credits directly to willing buyers. Tax equity...more

Blank Rome LLP

Arkansas Supreme Court Finds Auto Dealerships Liable for Sales Tax When They Provide Vehicles for Their Employees’ Use

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A recent decision from Arkansas’ highest court reversed a circuit court decision and found that when auto dealerships allowed employees and their families to use vehicles, it subjected the dealerships to sales tax, despite...more

Rivkin Radler LLP

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

Rivkin Radler LLP on

Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

Holland & Knight LLP

Consejo de Estado de Colombia: CDI con Reino Unido no activó cláusula de nación más favorecida

Holland & Knight LLP on

El CDI con Reino Unido no activó cláusula de nación más favorecida de los CDI con España, Suiza y Chile para servicios técnicos, de asistencia técnica y consultoría En Sentencia con Radicado 25411 del 4 de abril de 2024,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Tools for Investing Proceeds of Tax-Exempt Bonds

In a previous article, we introduced the fundamental concepts of the yield restriction and rebate rules set out in the Internal Revenue Code and Treasury Regulations and how tax-exempt bonds may be affected by high interest...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Propose Supplemental Notice Regarding Clean Hydrogen Production Tax Credit Regulations

On April 10, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of proposed rulemaking (the Supplemental Regulations) to supplement the Clean Hydrogen Production Tax...more

Freeman Law

Texas Sales and Use Tax For Equipment Rentals

Freeman Law on

Many businesses in Texas involve the performance of services that require the use of machinery and equipment. While these businesses may purchase the necessary equipment outright, others opt to rent equipment from...more

Locke Lord LLP

IRS Issues Guidance on Secure 2.0 – What Plan Sponsors Need to Know

Locke Lord LLP on

In late December 2023, approximately one year after Congress enacted the Setting Every Community Up for Retirement Enhancement Act of 2022 (“SECURE 2.0”), the Internal Revenue Service (the “IRS”) released Notice 2024-2 (the...more

Mintz - Tax Viewpoints

Canada’s 2024 Federal Budget: The Time Is Now ... to Lock in Lower Tax Rates

Mintz - Tax Viewpoints on

Tax practitioners will be busy in the coming weeks. Usually, in the lead-up to the issuance of the federal budget, released this year on April 16, 2024 (“Budget 2024”), there is speculation that the capital gains rate will be...more

Falcon Rappaport & Berkman LLP

For Tax Purposes, Are Limited Partners Really Limited Partners?

In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more

Davies Ward Phillips & Vineberg LLP

Federal Budget 2024: How It Impacts You and Your Business

On April 16, 2024 (Budget Day) the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2024). Budget 2024 included a number of proposed...more

Troutman Pepper

Preparing for IRS Cash Transaction Reporting in the Cannabis Industry

Troutman Pepper on

The various forms of information reporting required by the Internal Revenue Code form the backbone of both voluntary compliance with tax laws and the starting point for audits by the Internal Revenue Service (IRS). One form...more

Allen Barron, Inc.

You Need to Review Your Irrevocable Trust

Allen Barron, Inc. on

Do you employ an irrevocable trust or trusts as part of your estate plan? You need to review your irrevocable trust to ensure it still delivers the benefits intended. It is generally possible to modify an irrevocable trust,...more

McDermott Will & Emery

Weekly IRS Roundup April 8 – April 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 April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

Hodgson Russ LLP

Sales Tax Cases from the TiNY Blog for April 16, 2024

Hodgson Russ LLP on

Here are the sales tax cases from the TiNY Blog for the week of April 16, 2024. ...more

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Privacy Officer
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150 Harbor Drive, #2760
Sausalito, CA 94965

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Privacy Officer
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Sausalito, CA 94965

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Updates to This Policy

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