Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law
10 Things Lawyers Should Know About BVI Transactions
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
The Biden Tax Plan
Tax Planning Under a Biden Presidency
2020 Presidential Candidates' Tax Proposals
New anti-abuse provisions
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Impact of environmental, social and governance agenda on tax
This is the second edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 22, 2024 – July 26, 2024....more
El IRS se centra en las empresas desde la aprobación de la Ley de Reducción de la Inflación. Según el Plan Operativo Estratégico (financiado por la Ley de Reducción de la Inflación), el IRS está aumentando las tasas de...more
IRS is focused on Businesses since the passage of the Inflation Reduction Act. Under the Strategic Operating Plan (funded by the Inflation Reduction Act), the IRS is increasing audit rates, expanding enforcement and targeting...more
In Leto v. United States, the taxpayer reincorporated an S corporation business into a C corporation, then the taxpayer later sold the shares in the C corporation and tried to exclude the gain from such sale under section...more
On February 21, 2024, the IRS announced plans to increase funding under the Inflation Reduction Act to audit the use of corporate aircraft by large corporations, partnerships, and high-income individuals....more
On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more
Earlier today, the White House released its fiscal year (FY) 2025 budget request to Congress. Overall, it proposes $7.3 trillion in total spending, including a proposed $895 billion for defense and approximately $621 billion...more
Thanks to a dramatic increase in funding courtesy of the Inflation Reduction Act of 2022, the Internal Revenue Service recently announced several new, high-profile enforcement initiatives designed to generate significantly...more
The IRS recently provided guidance addressing inadvertent terminations of S Corporation (S Corp) status based on existing provisions in corporate documents that remain after a company makes an S Corp election. This can be a...more
On February 21, 2024, the Internal Revenue Service (IRS) announced plans to commence a focused audit effort targeting private aircraft usage by dozens of large corporations, large partnerships and high-income individual...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 22, 2024 – January 26, 2024....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 1, 2024 – January 5, 2024. ...more
Tax of counsel Fred Goldberg and senior advisor for tax resolution strategies De Lon Harris, both formerly of the IRS, joined the hosts of “GILTI Conscience” for a comprehensive look at current developments at the agency,...more
On December 15, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) issued Notice 2024-10 (the “Notice”), providing much needed interim guidance on the application of the Corporate...more
As described in our October 24 article “IRS Offers Forgiveness for Erroneous Employee Retention Credit Claims” the IRS has increased scrutiny on claims for the Employee Retention Credit (“ERC”). The IRS halted processing...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 2, 2023 – October 6, 2023. ...more
On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more
Federal legislation relating to the employee retention tax credit (“ERTC”), passed to alleviate the financial burdens of businesses shut down due to governmental orders during COVID, is discussed in a prior Client Advisory....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more
Treasury Department and IRS Release Preliminary Guidance on Semiconductor Tax Credit. On March 23, the Treasury Department and IRS published proposed regulations for implementing the new section 48D advanced manufacturing...more
Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more
On February 21, 2023, Treasury and the IRS issued T.D. 9972, finalizing regulations implementing the requirement to e-file certain information and tax returns. These regulations affect filers of partnership returns, corporate...more
Biden to Release 2024 Budget Proposal Later this Week. On March 9, President Joe Biden will send his updated budget proposal to Congress, outlining the administration’s policy priorities for fiscal year 2024. Biden is...more
TAX TIDBIT - Progress on Werfel and Blatchford Appointments, Other Nominations Delayed. Following the retirement of former IRS Commissioner Chuck Rettig in early November 2022, the tax-administration agency has been...more