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

A Win-Win for Independent Contractors and Hiring Companies: Alabama’s New Portable Benefit Accounts

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In an attempt to modernize benefits, Alabama has taken the bold step of being the first state to enact legislation allowing independent contractors to build portable benefit coverage. Traditionally, employee sponsored...more

Hogan Lovells

Property tax reform – The “Third Rail” of New York City politics?

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Early in his inaugural address, New York City Mayor Zohran Mamdani pledged to fix ‘a long-broken property tax system,' which is by far the single largest tax the City has, accounting for 43 percent of all tax collections....more

Mayer Brown

UK HMRC Pauses Concession on Failures to Withhold Tax on Interest Payments

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1. WHAT HAPPENED? HM Revenue & Customs (HMRC) has paused operation of its long‑standing practice under which, where UK‑source yearly interest was paid gross to a treaty-entitled overseas lender before HMRC clearance was...more

Morrison & Foerster LLP

Early Exercise of ISOs – Why It Doesn’t Work

“Early exercising” refers to exercising a stock option before it has fully vested, so you own the shares sooner (although they remain subject to the same vesting conditions as the stock option). For non-qualified stock...more

Akin Gump Strauss Hauer & Feld LLP

Speaking Sustainability - Legal & Regulatory Updates - December 2025

The 30th United Nations Climate Change Conference (COP30) ended on November 22, 2025. Among other things, the package of decisions reflected in the Belém Political Package brings renewed focus on scaling up climate finance...more

Bennett Jones LLP

Third Time's a Charm - CBSA Pushes Customs Valuation Reform

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For several years, the Canada Border Services Agency (CBSA) has sought to limit the ability of non-resident importers to self-assess duties, surtaxes and other taxes on imported goods based on their acquisition costs. In...more

McDermott Will & Schulte

Global equity plan reporting obligations for calendar-year 2026: Part one

Global equity plans are complex, and their administration requires collaboration across multiple departments, including legal, human resources, payroll, and tax....more

Orrick, Herrington & Sutcliffe LLP

Treasury targets alleged Minnesota benefits fraud in new set of actions

On January 9, the U.S. Treasury announced a series of measures aimed at addressing alleged widespread government benefits fraud in Minnesota, purporting that billions of taxpayer dollars were lost to what the Treasury deemed...more

A&O Shearman

UK Pensions: What’s new this week? January 2026 # 2

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Welcome to your weekly update from the A&O Shearman Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions....more

Fox Rothschild LLP

Making the Move: How to Appropriately Change Your Washington Domicile

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Washington has the highest estate tax rates in the country, with a top rate of 20 percent for taxable estates valued above $9 million. Under current law, this adds 12 percent to the total tax burden (meaning a taxable estate...more

Proskauer - Tax Talks

Treasury and the IRS Release Final and Proposed Regulations on Section 892

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On December 15, 2025, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) and proposed regulations (the “Proposed Regulations”)...more

Bracewell LLP

FEOC Rules for Clean Energy Tax Credits

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What Are the FEOC Rules and How Do They Impact Clean Energy Tax Credit Eligibility? The One Big Beautiful Bill Act (OBBBA) of 2025 introduced comprehensive foreign entity of concern (FEOC) rules that prohibit taxpayers...more

Mayer Brown

OECD Pillar Two Side-by-Side System and New Safe Harbors

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On January 5, 2026, the Organisation for Economic Co-operation and Development (“OECD”) announced that the Inclusive Framework on Base Erosion and Profit Shifting agreed to a new package of administrative guidance (the...more

Foley Hoag LLP - Cannabis and the Law

New Jersey Legislative Changes Implement Growth and Opportunity for Cannabis Marketplace

As 2025 ended and 2026 commenced with a flurry of legislative activity in New Jersey touching on cannabis businesses. These changes, as a whole, impact several material changes to the marketplace, including: (a) increasing...more

A&O Shearman

Italy’s 2026 Budget Law: practical takeaways for businesses

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The 2026 Italian Budget Law was published in the Italian Official Gazette on December 31, 2025. It introduces significant changes to Italy’s tax framework with material implications for investors, financial intermediaries,...more

Holland & Knight LLP

Revisión del Régimen Presencia Económica Significativa en Colombia

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Tradicionalmente, conforme a lo dispuesto en los artículos 24 y 408 del Estatuto Tributario (ET), en materia de servicios, solo se consideran ingresos de fuente nacional aquellos derivados de los que son prestados en...more

Holland & Knight LLP

OECD Pillar Two Side-by-Side Safe Harbor Package: Technical Review and Implications

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The Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework (Inclusive Framework) on January 5, 2026, released its Side-by-Side (SbS) Safe Harbor package (SbS Package) to streamline Pillar Two's...more

Pullman & Comley, LLC

Understanding Section 409A and Its Implications for Employers and Employment Agreements

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Prior to the enactment of Section 409A, no single section of the Internal Revenue Code governed taxation of nonqualified deferred compensation.  Income inclusion of deferred compensation was historically governed by a variety...more

McDermott Will & Schulte

Nuclear power projects gain momentum as federal tax incentives, data center demand transform financing landscape

With electricity demand rising across the United States, nuclear power is receiving renewed attention from energy developers, investors, and financiers – both for existing facilities and new projects....more

Husch Blackwell LLP

Hydrogen Used to Power Data Centers Is Taxable in Texas

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Investment in data centers continues to increase significantly as the country builds out infrastructure to accommodate the digital economy and growth of artificial intelligence. Many states, including Texas, have now...more

Goodwin

Unlocking the UPREIT Structure: A Comprehensive Guide to LTIP Units as Currency for Incentive Equity Awards

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The umbrella partnership real estate investment trust (“UPREIT”) structure, a cornerstone of the modern REIT industry, provides REITs with powerful tools for both property acquisitions and executive compensation. ...more

Schwabe, Williamson & Wyatt PC

IRS Final Rule on Tribal General Welfare Benefits: What It Means for ANCs and Tribal Governments

On December 16, 2025, the Internal Revenue Service issued a Final Rule implementing section 139E-1 of the Internal Revenue Code and the Tribal General Welfare Exclusion Act of 2014. The rule governs when benefits provided...more

Goodwin

Deadlines Approaching for Reporting 2025 ISO Exercises and ESPP Share Transfers

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The Internal Revenue Code (the Code), as amended, requires corporations to provide information statements to employees (including former employees) and information filings to the IRS regarding employees’ and former employees’...more

Bricker Graydon LLP

Foreign Entity of Concern Rules: A Quick Overview for Clean Energy Stakeholders

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The clean energy industry is at a crossroads. The One Big Beautiful Bill Act (OBBBA) introduced sweeping restrictions on Foreign Entities of Concern (FEOCs), fundamentally changing how developers, manufacturers, and investors...more

Williams Mullen

Estate Tax Portability: Tax Court Emphasizes Importance of Proper Filing

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In Estate of Rowland v. Commissioner, the Tax Court held that estate tax returns filed solely to elect portability must still be complete and properly prepared. Even when no estate tax is owed, missing asset-level information...more

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