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

Favorable Stock Buyback Regulations May Entitle Some Taxpayers to Refunds

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On November 21, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) under Section 4501, which imposes a 1% excise tax on certain...more

Foley & Lardner LLP

Updates for Overtime and Tip Reporting Obligations for 2025

Foley & Lardner LLP on

As we wrote on July 14, 2025, the One Big Beautiful Bill Act (OBBA) contains a provision providing a tax deduction for employees’ overtime income in 2025 through 2028....more

Procopio, Cory, Hargreaves & Savitch LLP

GAO Report Signals Intensified IRS Scrutiny of Puerto Rico Act 60 Residents

The U.S. Internal Revenue Service (IRS) appears to be entering a new and far more aggressive phase of enforcement focused on taxpayers claiming Puerto Rico residency and Act 60 (formerly Act 22) incentives or benefits. The...more

DarrowEverett LLP

Navigating Complex Asset Valuation in High-Net-Worth Divorces

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In high-net-worth (“HNW”), what you own is rarely the real battle, it’s what those assets are truly worth. HNW divorces bring unique financial and legal challenges that go far beyond traditional marital estate division....more

PilieroMazza PLLC

Passport to Trouble: Court Dismisses Foreign Bank Accountholders’ Penalty Challenge

PilieroMazza PLLC on

Enforcing foreign bank account reporting requirements through penalties has been an IRS priority for several years, spawning numerous precedent-setting cases throughout the courts. In the latest such case[1], a federal...more

Bricker Graydon LLP

Year-end Tax Challenges for Benefits While on Leave

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We get questions on administering benefits for employees on approved leaves year-round. But with the new year approaching, it is important to understand the tax issues affected by your administration of group health plan...more

Royer Cooper Cohen Braunfeld LLC

5 Easy But Effective Year-End Tax Strategies That Can Meaningfully Cut Your 2025 Tax Bill

As 2025 comes to a close, business owners and other high-income individuals still have an opportunity to make strategic moves that can materially reduce their tax liability and improve cash flow....more

Mayer Brown

Application du taux de marché à un prêt intragroupe par voie de réclamation

Mayer Brown on

Le Conseil d’Etat rend une décision sur une demande d’application de la règle dite du « taux de marché » prévue à l’article 212, I-a du Code général des impôts a posteriori sur réclamation du contribuable. Contrairement à...more

Mayer Brown

Bénéficiaire effectif et non-application d’un taux réduit de retenue à la source en présence de dividendes versés à une société...

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Le Tribunal administratif de Paris valide la remise en cause par l’administration fiscale du taux réduit de retenue à la source de 5 % prévu par la convention franco-luxembourgeoise en présence de dividendes versés à une...more

McDermott Will & Schulte

Potential refund opportunity of buyback excise tax based on § 4501 final regulations

McDermott Will & Schulte on

Taxpayers who paid the stock repurchase excise tax based on prior guidance provided in Notice 2023-2 and the proposed regulations under Internal Revenue Code (IRC) § 4501 may be entitled to a refund based on changes made in...more

Bradley Arant Boult Cummings LLP

How Will the Cannabis World Look When Marijuana Is Rescheduled? (UPDATED)

A few weeks ago, someone at a holiday party asked “Whitt, why doesn’t Budding Trends take on the weighty legal issues of the day and instead resort to cheap pop culture references and puns?” I thought about responding with a...more

Benesch

Mission India Update Following Implementation of Online Presence Review – Widespread Rescheduling of H-1B and H-4 Visa...

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This alert provides an update to our client communication issued last week regarding the Department of State’s new Online Presence Review requirement for H-1B applicants and their dependents. Following that announcement,...more

McDermott Will & Schulte

Treasury issues transition guidance for taxpayers with one-month deferral elections

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The Internal Revenue Service (IRS) recently released Notice 2025-72 as a preview of forthcoming regulations addressing the repeal of the one-month deferral election under Section 898(c)(2) and modifications to the treatment...more

Baker Botts L.L.P.

California 2026 Billionaire Tax Act

Baker Botts L.L.P. on

On October 22, 2025, a ballot initiative titled the “2026 Billionaire Tax Act” was filed with the California Attorney General. An amendment to the initiative was filed on November 26, 2025....more

Mayer Brown

Décision du Conseil d’Etat sur l’ordre d’imputation des déficits reportables en avant

Mayer Brown on

Le Conseil d’Etat tranche la question de l’ordre d’imputation des déficits reportables en avant : il retient une imputation selon un ordre strictement chronologique et en tire les conséquences pour l’application des règles de...more

DLA Piper

UK HC Confirms HMRC Should Consider Allowing Input VAT Recovery On Robust Alternative Evidence – Even Where No VAT Invoice Exists

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Hotelbeds UK Ltd operates as a wholesale supplier of hotel accommodation, purchasing rooms from UK VAT-registered hotels and reselling them to travel businesses. Due to industry practice, Hotelbeds struggled to obtain...more

DLA Piper

IRS Issues Notice 2025‑72 On Repeal Of The One‑Month Deferral Election

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The United States Internal Revenue Service (IRS) released Notice 2025‑72 (Notice) on November 25, 2025, addressing two issues arising from the repeal of the one‑month deferral election under Section 898(c)(2). Specifically,...more

DLA Piper

The General Court Of The CJEU Clarifies The Scope Of VAT Exempt Negotiation Services

DLA Piper on

The question referred to the Court was whether a comprehensive mortgage intermediation service that proactively sources clients, provides product information, assists with documentation, transmits and tracks proposals,...more

Davis Wright Tremaine LLP

What Employers Should Know About Tax Deductions for Qualified Tips and Overtime for 2025

Under the One Big Beautiful Bill Act (OBBBA), for tax years 2025-2028, eligible individuals can claim deductions for qualified tips and overtime compensation. The new law requires employers and other service recipients to...more

Snell & Wilmer

Ninth Circuit Holds That Tribal Officials Cannot Claim Sovereign Immunity or Qualified Immunity Under the Prevent All Cigarette...

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Recently, the Ninth Circuit Court of Appeals held that tribal officials could not claim sovereign immunity or qualified immunity from potential liability for failure to remit taxes on cigarette sales to the State of...more

Shumaker, Loop & Kendrick, LLP

Client Alert: ‘Tis the Season (and the Year) to Give — 2025

New Limits on Charitable Tax Benefits Coming in 2026 - As the end of 2025 quickly approaches, all taxpayers will have one last opportunity to review their tax planning and to consider making year-end gifts to one or more...more

Ius Laboris

New OECD Guidance on ‘Permanent Establishment’ and Overseas Employees

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The issue of whether an individual employed in one jurisdiction but working in another creates a taxable presence (a “permanent establishment” or “PE”) in the country in which the individual is working is a fundamental...more

Littler

Employment Regulatory Recap: 2025

Littler on

As 2026 approaches, many employers have been familiarizing themselves with new laws addressing everything from protected leaves to required employee notices and benefits offerings. Employers should also be aware of regulatory...more

Hogan Lovells

HL UK Pensions Law Digest 11 December 2025

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Pension Schemes Bill: Virgin Media remedy - Provisions in the Bill will enable retrospective validation of rule changes which may have otherwise been invalid, following the Court of Appeal’s decision in the Virgin Media case....more

DLA Piper

Life Sciences News in Italy: November 2025

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On 27 November 2025, Commission Decision (EU) 2025/2371 of 26 November 2025 declaring the functionality of the first four EUDAMED modules was published in the OJEU. ...more

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