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
Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more
Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more
Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more
The Massachusetts House and Senate voted in favor of a Massachusetts tax relief bill. The legislation is now on Governor Maura Healey’s desk, and she has until October 8th to act. More than two decades have passed since the...more
On March 9, 2023, the Biden Administration released the Fiscal Year 2024 Budget, and the “General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals,” which is commonly referred to as the “Green Book.”...more
Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER DUTCH LAW - Introduction - The purchase of an immovable property is a mutual agreement. Neither the seller nor the buyer has the obligation to make use of the services of...more
1. Types of Business Entities - 1.1 Description of the types of entities available in India through which to conduct business: A foreign entity may establish a business presence in India by: • opening a liaison...more
The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more
When incorporating a business, you may form a C corporation or S corporation. If you choose a C corporation, consideration should be given to qualifying the stock as “qualified small business stock” (“QSBS”)....more
The IRS has issued Revenue Procedure 2022-38, which sets forth inflation-adjusted items for various provisions of the Internal Revenue Code which will be applicable in 2023. Here are some of the highlights...more
On July 27, 2022, Senator Joe Manchin III (D-W.Va.) and Majority Leader Charles E. Schumer (D-N.Y.) introduced legislation entitled the “Inflation Reduction Act of 2022” (the “Reconciliation Bill”). The Reconciliation Bill is...more
On March 28, 2022, the Biden Administration released its budget proposal for Fiscal Year 2023 (the Budget). We summarize below the tax aspects of the Budget of particular interests to U.S. corporate taxpayers, financial...more
Effectively Connected Income - Unlike FDAP income, the United States taxes effectively connected income (“ECI”) on a net basis. Effectively connected income is income that is effectively connected with the conduct of a U.S....more
Section 1202 of the Internal Revenue Code provides savvy business founders and investors an opportunity for large tax savings. In fact, if the entity and the business exit are structured correctly, upon an exit, the founders...more
1. Introduction - In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability...more
Types of business entities - The two most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”) and the corporation (“Sociedad Anónima” or...more
Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more
It Seemed Like a Good Idea- In July of this year, one of my partners, who chairs the board of a local grantmaking public charity, asked if I would present at a CLE program to be sponsored by the charity on October 28 (last...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
The Cohan Rule: Tax Deductions with Incomplete Records - The “Cohan rule” is derived from the Second Circuit’s 1930 decision, Cohan v. Commissioner, which allowed the taxpayer to approximate travel and entertainment...more