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Stikeman Elliott LLP

Tax Court of Canada Denies GST/HST Input Tax Credit Claims in Connection with a Settlement Payment

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In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...more

Littler

Puerto Rico Department of the Treasury Announces 2025 Limits on Qualified Retirement Plans

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On January 23, 2025, the Puerto Rico Department of the Treasury issued Internal Revenue Circular Letter No. 24-01 (CL IR 24-01) announcing the applicable 2024 limits for Puerto Rico qualified retirement plans. Pursuant to...more

Baker Donelson

Reconciliation Bill's Potential Impact on EV and Infrastructure Ecosystem

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The Republican-controlled Congress is poised to pass key legislative measures through budget reconciliation that will impact the EV industry this year. Speaker Johnson favors a single reconciliation bill with an ambitious...more

Latham & Watkins LLP

Treasury Finalizes Controversial Regulations on IRS Penalty Oversight, but Debate Continues

Latham & Watkins LLP on

Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more

Adler Pollock & Sheehan P.C.

Financial Power of Attorney -To Spring or Not to Spring?

A financial power of attorney (POA) can be a critical component of your estate plan. It appoints a trusted representative (often called an agent) to make financial decisions on your behalf in the event you’re unable to do so....more

DLA Piper

Belgium - VAT: New Belgian Circular Letter on the VAT Implications of Credit Insurance - Monthly Indirect Tax Alert – January 2025

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Previously, for credit insurance covering the price of a supply including VAT, in so far as the credit insurer was subrogated in the rights of the insured supplier, the insurer was entitled to exercise the VAT refund right...more

Shook, Hardy & Bacon L.L.P.

Tax Considerations for Settlement Negotiations

Settlements in the employment law context can set up thorny tax issues for employers. In this alert, we will discuss two key issues companies should consider when working toward a settlement agreement: the deductibility of...more

DLA Piper

Brazil - VAT: Approval of the Supplementary Law on Tax Reform - Monthly Indirect Tax Alert – January 2025

DLA Piper on

On 16 January 2025, the President ratified Supplementary Law No. 214/2025, marking a significant step in Brazilian tax reform. This new law outlines the framework for the IBS, the CBS, and IS, while also establishing the IBS...more

Barnea Jaffa Lande & Co.

Recognition of Undocumented Construction Costs for Capital Gains Tax in Israel

The Israel Tax Authority (ITA) recently published an addendum to the 1987 circular  with the goal of minimizing disputes with sellers of residential apartments. The addendum contains procedures addressing instances when...more

Hogan Lovells

Proposed changes to preferential tax regimes enhance Hong Kong’s appeal to fund managers

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To foster a more competitive and favourable investment environment for funds and family offices, the Financial Services and Treasury Bureau issued a consultation paper (the “Consultation Paper”) in November 2024 outlining the...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

IRS releases catch up Roth Guidance

The Internal Revenue Service (“IRS”) issued proposed regulations regarding the provisions of the SECURE 2.0 Act of 2022 (“SECURE 2.0”) that relate to catch-up contributions....more

Maynard Nexsen

Tax Cuts and Cost of Insurance Litigation

Maynard Nexsen on

The Tax Cuts and Jobs Act (“TCJA”), also referred to as the “Trump Tax Cuts,” reduced the corporate tax rate from 35% to 21%. This law is in the news as the country’s leadership considers whether to extend the current...more

Foster Swift Collins & Smith

Legal-Ease: What Happens to Assets If I Do No Estate Planning at All?

Dear Jonathan: Based on my research, I feel like I’m pretty well versed in what I am supposed to do when it comes to creating an estate plan for myself. Everything I have read says that I should have a will, powers of...more

Moritt Hock & Hamroff LLP

MHH Condo/Co-op Digest, (February 2025)

This newsletter explores the emerging legal topics and issues affecting the condominium and cooperative services industry. Thought-leading attorneys from Moritt Hock & Hamroff’s Condominium and Cooperative Services Practice...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | February 2025 Special Tax Edition

Holland & Hart LLP on

Welcome to the buzz: Special Tax Edition. April 15 is just over two months away. This Special Tax Edition includes practical considerations to help you prepare for tax filing season, including: A former DOJ attorney...more

Nelson Mullins Riley & Scarborough LLP

Gold Dome Report - Legislative Day 12 - February 2025

As the sun appeared on the horizon on Wednesday, so too did the House’s version of the Amended FY 2025 State Budget. Synchronized perfectly with sunrise over Atlanta at 7:30 a.m., the House Appropriations subcommittees...more

Fenwick & West LLP

U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications

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The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more

Goodwin

How Are Private Investment Funds Structured?

Goodwin on

Private investment funds have investors and managers (or "sponsors"). Many private funds use partnership structures such as limited partnerships or limited liability companies (LLCs) taxed as partnerships to attract capital...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Eases Form 1095-C Burden for Employers

President Biden recently signed two new laws that significantly reduce the ACA compliance burden for employers by streamlining Form 1095 reporting and minimizing penalties for failure to file and distribute Form 1095s to...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Proposes New Rules to Implement the Expanded $1 Million Limit on Deductible Pay for Publicly Held Corporations

New proposed regulations under Section 162(m) of the Internal Revenue Code would further limit deductibility of executive compensation paid by a publicly held corporation....more

Cooley LLP

What to Know Before Acquihiring a Team

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Growing companies will often use acquihires to bring in a team of new employees. This can be more efficient and effective than hiring one by one, especially if the team being brought aboard works well together and has...more

Foley Hoag LLP

Annual Report Filing Reminders for DE, MA and NY

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This is a reminder that annual report filings are due in March 2025 for corporations formed or registered in Delaware and Massachusetts. New York biennial statements are due the last day of the calendar month in which a...more

Morgan Lewis

Expert Testimony May Be Limited if ‘Confidential’ Information Is Withheld Under Section 6103

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Expert witnesses can be critical to defending a tax position—but what happens when an expert must maintain confidentiality over information that is important to their analysis? Preserving this confidentiality while ensuring a...more

A&O Shearman

Trump administration's tariffs targeting China, Canada and Mexico

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On February 1, 2025, President Trump issued three Executive Orders (EOs) announcing tariffs on China (the China EO) Canada (the Canada EO), and Mexico (the Mexico EO), respectively, pursuant to the International Economic...more

DLA Piper

China - VAT: China's New VAT Law - Monthly Indirect Tax Alert – January 2025

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The new VAT law introduces several key changes including the scope of taxable transactions, clarification of "deemed sales", non-taxable items, tax rates and more....more

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