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Firm Profile: Proskauer Rose LLP
Eleven Times Square
(Eighth Avenue & 41st Street)
New York, NY 10036-8299, United States
Phone: 212.969.3000
Fax: 212.969.2900
Areas Of Practice
  • Taxation
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California Franchise Tax Board (FTB) to Apply Market-Based Sourcing Rules to Nonresident Directors of California Based Corporations

On Monday, September 9, 2024, the California FTB approved proposed amendments to California’s personal income tax code. This proposed rule would impose California income tax on non-resident/non-employee corporate directors…more
 /  Business Organizations, Franchise Law, Taxation

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term of…more
 /  Business Organizations, Commercial Law & Contracts, Finance & Banking, Taxation

UK government consults on taxation of carried interest

The newly elected UK Labour government published its call for evidence (see link here) on the taxation of carried interest on Monday 29 July 2024. This consultation by HM Treasury, cautiously anticipated following statements…more
 /  Finance & Banking, Taxation

UK Supreme Court confirms no deduction for expenses related to share and asset sale

On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of a…more
 /  Business Organizations, International Law & Trade, Mergers & Acquisitions, Taxation

Supreme Court Rules on Moore v. U.S. – Upholds Mandatory Repatriation Tax

On June 20, 2024, the U.S. Supreme Court ruled 7-2 that the so called mandatory repatriation tax under Internal Revenue Code Section 965 (“MRT”) is constitutional. Justice Kavanaugh wrote the majority opinion..…more
 /  Constitutional Law, International Law & Trade, Taxation

Treasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to Develop Further Partnership Guidance.

On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working group”…more
 /  Business Organizations, Taxation

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on the…more
 /  Business Organizations, Mergers & Acquisitions, Taxation

Final Regulations on Domestically Controlled REITs

On April 24, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations on the definition of “domestically controlled” real estate investment trusts (“REITs”)…more
 /  Administrative Law, Finance & Banking

Summary of the Biden Administration’s Fiscal Year 2025 Green Book Tax Proposals

On March 11, 2024, the Biden Administration released the Fiscal Year 2025 Budget, and the “General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals,” which is commonly referred to as the “Green Book.” The…more
 /  International Law & Trade, Taxation

Change to non-domicile tax regime forms part of UK Spring Budget 2024

As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the…more
 /  Finance & Banking, Taxation, Wills, Trusts, & Estate Planning

Recent Updates from the IRS and Treasury on the Superfund Chemical Tax

I. Executive Summary - On February 15, 2024, the IRS and Treasury issued a supplemental notice to a prior notice from December 2022, to correct a petition requesting that the Superfund Chemical Tax apply to polyphenylene…more
 /  Environmental Law, Taxation, Toxic Torts, Zoning, Planning & Land Use

Tax Relief for American Families and Workers Act of 2024

On January 17, 2024, Senate Finance Committee Chairman Ron Wyden (D-Ore.) and House Ways and Means Committee Chairman Jason Smith (R-Mo.) released a bill, the “Tax Relief for American Families and Workers Act of 2024” (“TRAFA”…more
 /  Administrative Law, Taxation

HMRC updates guidance on UK tax status of non-UK entities and US LLCs post Anson

On 6 December, HMRC updated the section in its International Manual discussing the UK tax characterisation of overseas entities, and of Delaware (and other US) limited liability companies (LLCs) in particular (in INTM180000 and…more
 /  Business Organizations, International Law & Trade, Taxation

Tax Court holds that an offshore fund is engaged in a U.S. trade or business

On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio companies…more
 /  Business Organizations, Finance & Banking, International Law & Trade, Taxation

Tax Court Holds That Active Limited Partners of State Law Limited Partnerships May Subject to Self-Employment Tax

Section 1402(a)(13) of the Internal Revenue Code provides that the distributive share of “limited partners, as such” from a partnership is not subject to self-employment tax.[1] Managers of private equity and hedge funds are…more
 /  Taxation
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