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
For an active business in the post-Tax Cuts and Jobs Act (TCJA) world of lower corporate tax rates, buyers and shareholders considering a future exit should always consider C corporations and the availability of potential...more
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
When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...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
[co-author: Mourice Okon] a) Types of business entities in Kenya - Kenya has 5 main types of business entities that is, sole proprietorships, partnerships, limited liability partnerships, companies, non-governmental...more
ESTABLISHING A BUSINESS ENTITY IN HONG KONG - 1. Introduction - Hong Kong as an international centre for finance, commerce and trade is often considered as one of the most attractive places to do business owing to...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
The Budget Law extends the applicability of the Italian participation exemption regime (Italian PEX) to companies and trade entities which are resident in an EU or EEA member State (that allows an adequate exchange of...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
The Washington Supreme Court recently upheld as constitutional the state’s capital gains tax (WA Cap Gains Tax) that was enacted in 2021. The new WA Cap Gains Tax creates new wrinkles and provides new planning opportunities...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
On Friday, 24 March 2023, the Washington Supreme Court upheld the state’s capital gains tax (the WA CGT) in a 7–2 decision, bringing an end to months of uncertainty as a suit to challenge the new tax worked its way through...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
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves 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
Summary - ..Based upon a change of law as from 2021 German property companies are allowed to deliver electricity and earn income from contractual relationships with their tenants within certain thresholds without...more
Section 1202 is a once-obscure tax saving provision that has come into prominence in the last few years. Originally passed in 1993 as a 50% capital gain exclusion, it has been amended several times since. In its current...more