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Tax Intellectual Property

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

Regulatory & Risk Advisory Review: Cayman Islands – July to September 2024

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Welcome to the third Regulatory & Risk Advisory Review instalment of 2024. In this edition we cover the latest Cayman Islands regulatory updates including the Beneficial Ownership Transparency Act and The Perpetuities...more

Cadwalader, Wickersham & Taft LLP

Treasury and IRS Release Proposed Corporate Alternative Minimum Tax Regulations

On September 13, 2024, in the Federal Register, the Treasury and IRS published proposed regulations implementing the corporate alternative minimum tax (“CAMT”).  Its 182 pages (including 62 pages of preamble) describe a...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: U.S. Tax Reporting for Americans That Live Overseas and Voluntary...

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Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more

Cadwalader, Wickersham & Taft LLP

The Tax Reform Ghost Returns for the Expiring TCJA Provisions

Many tax provisions enacted under the Tax Cuts and Jobs Act (the “TCJA”) will automatically expire on December 31, 2025, and others will expire by December 31, 2028.  As previously discussed here, the pressing need to address...more

Kaufman & Canoles

Corporate Transparency Act - October 2024

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The Corporate Transparency Act (“CTA”) has been in effect since January 1, 2024, imposing significant reporting obligations for millions of privately held entities, called Reporting Companies. For Reporting Companies in...more

Holland & Knight LLP

A Look at Search Funds and Section 1202 Qualified Small Business Stock

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Search Funds should consider the availability of the tax benefits of Section 1202 in connection with their acquisitions. The upside, if properly structured, can be significant. Section 1202 has gained popularity likely due to...more

Potomac Law Group, PLLC

Can a Disadvantaged Individual Hold Their DBE Ownership in Trust? Recent Revisions to the Regulations Are Unclear

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Many business owners consult with accounting and tax professionals on how to best accomplish their financial goals and estate planning, but sometimes those decisions run afoul of what is allowable under the Disadvantaged...more

Mandelbaum Barrett PC

Going Global: Legal Tips for International Business Expansion

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Venturing into the international market is ideal for business expansion, however, it brings along a myriad of legal hurdles. Review these essential guidelines to ensure that your global expansion is smooth and successful....more

Downs Rachlin Martin PLLC

What Connelly v. United States Means for Closely-Held Businesses

The US Supreme Court recently issued a significant decision, impacting many closely-held businesses with buy-sell agreements funded by life insurance policies, Connelly v. United States, 144 S. Ct. 1406 (2024). In a 9-0...more

Foster Garvey PC

A Birthday Greeting to the Tax Reform Act of 1986

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The Tax Reform Act of 1986 (the “TRA 86”) was signed into law by President Ronald Reagan on October 22, 1986, exactly 38 years ago today. TRA 86 was sponsored by, among others, Representative Richard Gephardt (D-Missouri) in...more

Adler Pollock & Sheehan P.C.

Estate Planning Pitfall: You Haven’t Properly Funded a Trust

A trust can form the cornerstone of your estate plan, and trusts come in a variety of flavors. Indeed, there’s one for nearly any estate planning situation. Here’s a brief list of a trust’s potential advantages: trust assets...more

DLA Piper

IRS Approves New REIT With No Initial Income or Assets

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On October 4, 2024, the Treasury Department released a private letter ruling (PLR 202440007, or the PLR) addressing whether a real estate investment trust (REIT) without any income and assets in its first year of operation...more

Blake, Cassels & Graydon LLP

Comprendre les régimes de rémunération des hauts dirigeants dans le cadre de F&A

Les transitions effectuées au sein des équipes de direction dans le cadre d’opérations de fusions et acquisitions (« F&A ») peuvent poser de nombreux défis juridiques et financiers relativement à la rémunération des hauts...more

Freeman Law

IRS to Ramp Up Tax Compliance Efforts In Connection with Wagering and Gambling

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On September 30, 2024, the Treasury Inspector General for Tax Administration (“TIGTA”) issued a report evaluating the IRS’s enforcement efforts relating to taxpayers with gambling and wagering winnings....more

Kilpatrick

5 Key Takeaways - Income Tax Jeopardy! A Potpourri of Hot Topics

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Kilpatrick’s David Hughes recently participated in a panel discussion at the Taxpayers’ Federation of Illinois annual state and local tax conference in Rolling Meadows, Illinois. David’s session, “Income Tax Jeopardy! A...more

Falcon Rappaport & Berkman LLP

No Tax on Tips: Pragmatic Tax Proposal or Populist Tax Policy Nightmare?

Recently, both major-party presidential candidates have come out in favor of a “no tax on tips” proposals, though neither candidate has indicated how to implement one. There have been proposals from other legislators, though...more

Carey Olsen

Bermuda corporate and finance update Q2 2024

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Our corporate team outline the latest developments within the corporate and finance market in Bermuda including Bermuda’s Corporate Income Tax Act 2023, Cyber risk management and The Bermuda Monetary Authority's enhancements...more

Vicente LLP

Cannabis Rescheduling: Timeline, Tax Strategies & 280E

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As the cannabis rescheduling process progresses and we enter the fourth quarter of 2024, many cannabis businesses are wondering what’s next and how rescheduling may impact 280E and tax planning. In this session, Vicente...more

Holland & Knight LLP

Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election

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Private Wealth Services attorneys Patrick Duffey and Brent Berselli discuss the future of tax policy with Tax attorney Joshua Odintz ahead of the 2024 election. The attorneys provide an overview of the 2017 Tax Cuts and Jobs...more

Allen Barron, Inc.

The Action Cryptocurrency Investors Need to Take Immediately

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What is the action cryptocurrency investors need to take immediately? What has changed, and why should any digital asset holder or investor pay attention to this game-changing development? Here is the short answer: If...more

Clark Hill PLC

Criterio No Vinculativo 44/Isr/NV: Requisitos Para la Deducibilidad de Erogaciones Por Prestación de Servicios

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Nota: El 11 de octubre de 2024, se publicó en el Diario Oficial de la Federación (DOF) la incorporación al Anexo 3 del criterio de referencia, relativo a los requisitos de indispensabilidad que deben cumplir las erogaciones...more

Clark Hill PLC

Nonbinding Criterion 44/ISR/NV: Requirements for the Deductibility of Expenses In Exchange for Provision of Services

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On Oct. 11, the incorporation of the referenced criterion into Annex 3 was published in the Federal Register, regarding the requirements that expenses for the provision of services must meet in order to be deductible....more

Clark Hill PLC

Alternatives to Consider in Tax Procedures Following the Judicial Reform in Mexico

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Note: On Sept. 15, 2024, the “Decree amending, adding, and repealing various provisions of the Constitution of the United Mexican States on the Federal Judiciary” (the “judicial reform” or “reform”) was published in the...more

Clark Hill PLC

Alternativas a Considerar en Procedimientos Fiscales Ante la Reforma al Poder Judicial de la Federación

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Nota: El 15 de septiembre de 2024, fue publicado en el Diario Oficial de la Federación (“DOF”) el “Decreto por el que se reforman, adicionan y derogan diversas disposiciones de la Constitución Política de los Estados Unidos...more

Amundsen Davis LLC

Losing Land to Eminent Domain? Plan for Tax Consequences Using an Internal Revenue Code Section 1033 Exchange

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Under general tax rules, if the government takes your property through eminent domain and pays you condemnation proceeds, you may have to pay capital gains (or any depreciation recapture) tax if the condemnation proceeds...more

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