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
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
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
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
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
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
On March 20, 2020, the US Department of the Treasury extended the deadline for filing 2019 federal income tax returns to coincide with the extended deadline for making federal income tax payments. Accordingly, the due date...more
In the early hours of March 20, Treasury Secretary Steven Mnuchin announced that the Internal Revenue Service (IRS) has extended the deadline for filing of federal income tax returns to July 15, 2020. All individuals and...more
In its latest response to the COVID-19 pandemic, the U.S. Treasury Department today announced that the traditional income tax return filing deadline would be moved from April 15th, 2020 to July 15th, 2020....more
The day after the Oklahoma Tax Commission followed the previous guidance issued by the Internal Revenue Service to allow taxpayers to defer income tax payments but not filing requirements, U.S. Treasury Secretary Steven...more
Two days after extending by 90 days the deadline for payment of certain federal income taxes, on March 20, US Secretary of the Treasury Steven Mnuchin announced that the Internal Revenue Service will also extend the deadline...more
On March 18, 2020, the IRS issued Notice 2020-17 announcing the extension of the due date for the payment of federal income taxes due April 15, 2020 until July 15, 2020, with no interest, penalties or additions to tax...more
The Treasury Department extends the US federal tax filing deadline from April 15 to July 15. This week’s surge in the number of confirmed COVID-19 cases was accompanied by frequent responses at the federal level directed at...more
In guidance published March 18, 2020 (Notice 2020-17), the Internal Revenue Service (IRS) postponed the payment deadline from April 15, 2020, until July 15, 2020, for federal income tax payments (including payments of tax on...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9 – 13, 2019. September 9, 2019: The IRS released a revision to its Internal Revenue...more
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: ..Transfer pricing for “captive” services...more
Most non-US persons who are properly advised regarding US real estate ownership will structure their holdings to include some combination of US LLCs, non-US companies, non-US partnerships, non-US trusts and/or non-US...more
As noted on our Benefits Notes blog, on August 21, 2018, the IRS issued its initial guidance on the amendments to Section 162(m) made by the Tax Cuts and Jobs Act, in the form of Notice 2018-68. The guidance is fairly limited...more