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

Freeman Law on

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

Proskauer - Tax Talks on

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?

Rivkin Radler LLP on

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

Fox Rothschild LLP on

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?

Foodman CPAs & Advisors on

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

Husch Blackwell LLP on

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

Mintz - Tax Viewpoints on

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

Verrill on

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

Barnea Jaffa Lande & Co. on

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

Carey Olsen

A guide to blockchain and cryptocurrency regulation 2024: British Virgin Islands (GLI chapter)

Carey Olsen on

Chris Duncan and Katrina Lindsay have authored the British Virgin Islands (BVI) chapter of Global Legal Insight's sixth edition guide to blockchain and cryptocurrency regulation. The chapter covers the BVI legal requirements...more

Crunched Credit

The Administrative Illuminati in Pursuit of Command and Control (Or the Unmentionable in Hot Pursuit of the Inedible with...

Crunched Credit on

The way we regulate rarely works terribly well for the regulator or the regulated.  Yet, we keep doing it the same way…a subspecies of insanity to be sure.   As an example, has anyone out there in CRE land taken a gander at...more

Burr & Forman

Corporate Transparency Act Filing Deadlines Approaching - What You Need to Know, Part I

Burr & Forman on

The Corporate Transparency Act (CTA) requires “reporting companies” to report certain beneficial ownership information (BOI) to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) in order to enhance...more

ASKramer Law

Energy Tax Credits for a New World Part IX: Overview of Changes to Traditional Tax Equity Financing

ASKramer Law on

Tax equity investments in 2023 were about $20 billion annually. To meet the goals of the Inflation Reduction Act (IRA), “many forecasters estimate that tax equity will need to increase […] to over $50 billion.”...more

Morgan Lewis

Finance Ministry Circular on the Tax Recognition of Incongruent Profit Distributions

Morgan Lewis on

In its ruling dated September 28, 2022 (VIII R 20/20), the Federal Fiscal Court (BFH) decided, contrary to the previous opinion of the tax authorities, that a resolution on an incongruent distribution of a limited liability...more

Morgan Lewis

Exchange Rate Losses from Shareholder Loans Granted by Substantial Shareholders Are Not Tax-Deductible

Morgan Lewis on

In its decision dated April 24, 2024 (I R 41/20), the Federal Fiscal Court (BFH) decided for the legal status up to December 31, 2021 that exchange rate losses from loans granted by a substantial shareholder (>25 %) are not...more

Morgan Lewis

Changes to German Tax Law - What Is Planned?

Morgan Lewis on

The German legislator is currently introducing a large number of tax law changes in various draft bills. This article provides an overview of the most important planned changes. The draft Annual Tax Act 2024 (JStG 2024)...more

Levenfeld Pearlstein, LLC

‘Danger, Will Robinson’: The IRS Increases Scrutiny of Conservation Easements

Sometimes tax motives overwhelm philanthropic motives, which has often been the case with charitable deductions for so-called “conservation easements.” For years now, sponsors have offered up investments in partnerships,...more

Cozen O'Connor

Cozen Currents: Getting Down to Brass Tacks on Tax Reform

Cozen O'Connor on

The Cozen Lens - · Tax reform will be the top legislative issue next year regardless of who wins the elections and Congress, not the White House, will be the ones in the driver’s seat. · The Supreme Court begins its...more

Akin Gump Strauss Hauer & Feld LLP

This Week's Climate Policy Update - September 30 - October 4, 2024

Good morning! This is Akin’s newsletter on climate change policy and regulatory developments, providing information on major climate policy headlines from the past week and forthcoming climate-related events and hearings...more

Littler

Unlocking New Benefits: Is the SECURE 2.0 Student Loan Match Right for Your Workforce?

Littler on

Employers now have a new benefit option in their toolbelt: The Qualified Student Loan Payment (QSLP) match. But is it worth implementing? Before diving into the specific legal requirements for a QSLP match program, this...more

Mintz - Employment Viewpoints

Hiring Across the 49th Parallel: Traps for the Unwary for Cross-Border US-Canada Hires (Part II)

The United States and Canada are each other’s largest trade partners with nearly C$3.6 billion/US$2.7 billion worth of goods and services crossing the border each day in 2023. The United States is the single greatest...more

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