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
Before forming any entity, founders need to make two fundamental decisions: which entity type is best for their business operations and which tax classification is best for the owners. Although the entity type and tax...more
As described in more detail in our recent client bulletin, BVI companies are now required to prepare and file with their registered agent an “annual return” containing a basic balance sheet and income statement. This annual...more
1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 26, 2024 – March 1, 2024. ...more
Our Doing Business in Québec guide provides an overview of the legal framework governing Canadian business operations in the province of Québec. This guide provides up-to-date information about the following topics: •...more
South Carolina companies with any real or personal property placed in service in the state annually complete and file a PT-300, the state’s property tax return form. Companies that have entered into a negotiated Fee in Lieu...more
On June 7, 2023, the IRS released Notice 2023-42 (the Notice), providing taxpayers relief from the addition to tax under Section 6655 in connection with the application of the new corporate alternative minimum tax (CAMT). In...more
Welcome to the latest edition of our Quarterly Corporate Update covering recent developments in the British Virgin Islands. The first quarter of 2023 saw a raft of amendments to existing BVI legislation being introduced...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
While there are a few different forms of “corporate” entities in Israel, this guide will focus on companies and partnerships as these are the entities that the non-Israeli businessman is most likely to set up or invest in if...more
On December 22, 2022, the Internal Revenue Service (IRS) finalized changes to Schedule UTP, Uncertain Tax Position Statement, and Instructions for Schedule UTP. Proposed changes to Schedule UTP and the UTP Instructions were...more
U.S. partners in U.S. partnerships that invest in PFICs may soon be responsible for filing elections previously filed by the partnership. Under current regulations, U.S. partners may rely on entity-level mark-to-market...more
1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the world’s...more
On October 15, 2021, the IRS published Information Release 2021-203, based on Memorandum 20214101F (the "Memorandum") prepared by Field Attorneys in the Office of Chief Counsel, setting out a detailed procedure requiring...more
In today's blog, we look at the most draconian tax rule in the world and examine whether the rule is valid. In addition, we examine a recent United States Tax Court case where the court upheld this draconian rule against a UK...more
How is taxable income determined in your state? To what extent is the state income tax base aligned with the federal income tax base? Alabama levies a corporate income tax on business entities classified as taxable or “C”...more
Because of Covid-19, the IRS extended most federal tax filing and payment deadlines otherwise due from April 1, 2020 to July 14, 2020 until July 15, 2020....more
The Internal Revenue Service has expanded its previous relief measures with Notice 2020-23, which automatically extends key tax deadlines for all taxpayers that have a filing or payment deadline on or after April 1, 2020, and...more
On March 21, 2020, the Treasury Department and the Internal Revenue Service issued Notice 2020-18, which announced that the federal income tax filing and payment due date is automatically extended from April 15, 2020, to July...more
Seyfarth Synopsis: On March 25, 2020, the Internal Revenue Service (“IRS”) announced its “People First Initiative” (the “Initiative”), which will provide relief to taxpayers by suspending payments under certain collection...more
Seyfarth Synopsis: The tax credits afforded to certain employers and self-employed individuals by the Families First Coronavirus Response Act (FFCRA) are in effect for the period from April 1, 2020 to December 31, 2020. ...more
March 24, 2020 As COVID-19 has been disrupting our personal and professional lives, the April 15 tax deadline continued to loom on the horizon. In welcome news for many, on Friday, Treasury Secretary Steven Mnuchin announced,...more
UPDATE - On March 20, 2020, the Treasury Department issued Notice 2020-18, which further clarifies the scope of the 90-day tax extension first announced on March 17, 2020, and which supersedes earlier guidance issued on March...more
Following U.S. Treasury Secretary Steve Mnuchin’s announcement via Twitter on Friday, March 20, that Treasury would be moving Tax Day from April 15 to July 15, New York Governor Andrew Cuomo’s Budget Director Robert Mujica...more