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Ius Laboris

Tax Relief for Those Moving (Back)

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Many countries have special personal income tax regimes for individuals performing work on their territory and we will be covering some of these regimes in a series of articles. In this article we discuss Return Tax Relief...more

Farrell Fritz, P.C.

New Savings Opportunity – Converting a 529 Plan to Roth IRA

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Recent changes implemented by Secure Act 2.0 provide a powerful retirement opportunity. Starting in 2024, Congress changed the way that 529 accounts work....more

Mayer Brown

STF's Relevant Tax Decisions of the Week

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Last week, the Brazilian Supreme Court (STF) issued decisions on two relevant tax issues: (i) the effective reduction in percentage of the amounts reimbursed to exporters under the Special Regime for the Reintegration of Tax...more

Mayer Brown

Brazil Publishes Provisional Measure Introducing Additional CSLL to Adapt to OECD GloBE Rules

Mayer Brown on

On October 3, 2024, Provisional Measure (PM) No. 1,262/2024 was enacted, introducing an addition to the Social Contribution on Net Income (the “Additional CSLL”), in order to adapt to the Organisation for Economic...more

McDermott Will & Emery

Back-to-School Special: IRS Offers Insight Into Matching Qualified Student Loan Payments

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On August 19, 2024, the Internal Revenue Service (IRS) issued Notice 2024-63 (the Notice), providing guidance regarding the implementation of Section 110 of the SECURE 2.0 Act of 2022 (SECURE 2.0), which permits employers...more

Fleurinord Law PLLC

Beyoncé vs. the IRS: The Surprising Details About Queen Bey’s $2.9 Million Tax Dispute

Fleurinord Law PLLC on

Even global icons like Beyoncé, among the wealthiest entertainers on the planet, are not immune to IRS scrutiny. Recently, Queen Bey found herself entangled in a dispute with the Internal Revenue Service (IRS) over an alleged...more

Amundsen Davis LLC

Eligibility for Significant Savings From the Sale of Qualified Small Business Stock Under Internal Revenue Code Section 1202

Amundsen Davis LLC on

If you own a small business, you may qualify for significant tax savings under section 1202 of the Internal Revenue Code of 1986, as amended (Section 1202). Owners or investors of certain C corporations (C corps) may be...more

A&O Shearman

Luxembourg RCS: what are the new requirements as of 12 November 2024?

A&O Shearman on

As of November 12, 2024, all individuals registered or to be registered within a file of an entity itself registered with the Luxembourg trade and companies register (RCS) will be required to communicate or request a...more

A&O Shearman

Fifth Circuit Securities Litigation Quarterly: Third Quarter 2024

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Welcome to the Q3 2024 edition of A&O Shearman’s Fifth Circuit Securities Litigation Quarterly. As public companies and financial institutions continue to migrate to Texas, our Texas-based securities litigation team continues...more

Buckingham, Doolittle & Burroughs, LLC

Upcoming Deadline for Beneficial Ownership Information Reports Under the Corporate Transparency Act (CTA)

Effective January 1, 2024, the Corporate Transparency Act (the “Act”) requires many U.S. businesses to disclose information regarding their beneficial owners. Failure to comply with the Act can result in significant civil and...more

Verrill

IRS Provides Helpful Answers Regarding Long-Term Part-Time Employees in 403(b) Plans

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In November 2023, the IRS issued proposed regulations addressing the SECURE 2.0 long-term part-time (LTPT) employee eligibility requirements applicable to 401(k) plans knowing that further guidance would be needed to explain...more

Ankura

The Benefits of Recognizing Personal Goodwill in a Transaction

Ankura on

There is a little-known asset – personal goodwill – that is present in certain types of businesses and can potentially provide a significant tax benefit when identified as part of a transaction. This article will clarify what...more

Walkers

Cayman Islands Regulatory Update - Q4 2024

Walkers on

Update to the Cayman Islands beneficial ownership reporting regime - Following industry consultation, the Beneficial Ownership Transparency Act ("BOTA") was gazetted on 15 December 2023 and commenced on 31 July 2024,...more

Freeman Law

Is Your Business Subject to the Texas Franchise Tax?

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As noted in a prior post, the Texas franchise tax is a tax imposed on any “taxable entity” that does business in Texas or that is chartered or organized in Texas. This begs the question – “Which entities are taxable, and...more

Bergeson & Campbell, P.C.

With Less Than One Month until Election Day, a Growing List of Policy Issues Needs Attention during the Lame Duck Session

The list of pending issues that Congress could consider during the lame duck session in 2024 continues to grow. The list includes “must pass” items, including appropriations to fund the government through the remainder of...more

Proskauer - Tax Talks

No Money? No Problem: Recent IRS Favorable Guidance Regarding a REIT’s First Year

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On October 4, 2024, the Internal Revenue Service (the “IRS”) released Private Letter Ruling 202440007, which concluded that the lack of income and assets in the first taxable year of an entity that had elected to be treated...more

Rivkin Radler LLP

Thinking About Making Taxable Gifts Before the 2026 Sunset?

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As we will see shortly, it is often “better to give than to receive,” though this statement begs the obvious question of whether it is better to do so during one’s lifetime or upon one’s death. Many well-to-do individuals...more

Fox Rothschild LLP

IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel

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In Notice 2024-72, the IRS provided relief for individuals and businesses affected by terrorism in the State of Israel beginning on September 30, 2024. The new notice provides additional relief to taxpayers in Israel, as well...more

Foodman CPAs & Advisors

Are Crowdfunding Monies Taxable?

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On August 2024, the IRS, for the third time in two years, reminded taxpayers that crowdfunding monies may be taxable. Due to the popularity of crowdfunding monies raised online, the IRS issued News regarding how money raised...more

Husch Blackwell LLP

Comparing IRA Section 48 to Section 48E Investment Tax Credits for Biogas Projects

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As year’s end approaches and biogas developers turn from Section 48 investment tax credits (“ITCs”) under the Inflation Reduction Act of 2022 (the “Act”), which required projects to begin construction before December 31,...more

Procopio, Cory, Hargreaves & Savitch LLP

Considerations for Taxable Estate Owners with a Beneficial Tax Provision Possibly Expiring

A key benefit to families with taxable estates may be about to go away. The Tax Reform Act of 2017 incorporated numerous tax reductions into U.S. law, with one significantly increasing the ability of taxable estate owners to...more

Smith Anderson

Tapping Retirement Savings After Tropical Storm Helene

Smith Anderson on

Our heartfelt thoughts are with everyone affected by Tropical Storm Helene. Your safety and well-being are paramount and we are here to support those impacted during this challenging time. As employees and employers work...more

Mintz - Tax Viewpoints

F-Reorgs: How Buyers’ and Sellers’ Favorite ‘F Word’ Optimizes M&A and Private Equity Transactions Involving S Corporations

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In M&A and private equity transactions, buyers and sellers are consistently looking for ways to maximize value, which requires a critical focus on structuring the transaction in a tax-efficient manner. This pursuit of tax...more

Verrill

CTA Compliance Check-In #2

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In June we circulated an article entitled “Mid-year assessment: Are you in good shape on CTA compliance?” The Corporate Transparency Act (CTA) deadline for filing BOI reports with FinCEN is now less than three months away –...more

Barnea Jaffa Lande & Co.

Tax innovations in Israel during 2024

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Over the past year, alongside handling the economic repercussions of the war and issuing financial assistance to war victims and to evacuees, the courts, the legislative authority and the Israel Tax Authority continued their...more

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