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
Spin-offs have become increasingly popular with innovative companies as a method of unlocking shareholder value, but the transaction is not always tax-free, particularly for international employees holding equity awards or...more
UK Case Law Developments - Income tax consequences of pension-related payments in E.ON v HMRC - E.ON v HMRC concerned a large UK power and gas supplier, which paid certain lump sum payments, called “facilitation...more
The Spanish Supreme Court has recently issued a judgment concluding that a Canadian pension qualifies for the same tax treatment as Spanish pension funds and is therefore entitled to obtain the refund of the withholding tax...more
On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more
The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19 – 23, 2019. August 20, 2019: The IRS released a proposed regulation that provides...more
Do you provide parking for your employees? If so, take note: the expense has gone up (and, for tax-exempt employers, may now result in additional tax liability!)....more
Marissa Holob is chair of the firm’s Executive Compensation and Employee Benefits practice. She advises clients on a wide range of executive compensation and employee benefits issues, including those that arise in the context...more
The Internal Revenue Service (the “IRS”) recently issued Notice 2018-68 (the “Notice”) that provides guidance regarding the application of Section 162(m) of the Internal Revenue Code of 1986, as amended (“Section 162(m)”)...more
On August 21, the Internal Revenue Service (IRS) issued Notice 2018-68 containing much-awaited interpretive guidance on Section 162(m) of the Internal Revenue Code as amended by last year's tax reform act (Tax Act), including...more
On August 21, the IRS issued Notice 2018-68 to provide guidance on changes to Internal Revenue Code Section 162(m), enacted by the Tax Cuts and Jobs Act of 2017 (TCJA). Section 162(m) generally limits the tax deduction...more
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 and does not completely address...more
Under the Tax Cuts and Jobs Act (the “Act”) employers are no longer allowed to take a deduction for qualified transportation fringe benefits provided to employees (other than qualified bicycle commuting reimbursements which...more
The Tax Cuts and Jobs Act (the “Tax Act”) has significant implications for public company executive compensation plans for tax years beginning after December 31, 2017 and will likely have a considerable impact on the future...more
Tax reform made few changes that directly impact qualified retirement plans; however, it made some changes that may indirectly impact qualified retirement plans. We previously blogged on the indirect changes that tax reform...more
NEW TAX LAW MAKES CHANGES TO COMMUTING BENEFITS - ...The Tax Cuts and Jobs Act of 2017 (“TCJA”) generally eliminates employer deductions for commuter transportation and parking fringe benefits. This includes deductions...more
On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (H.R. 1), or the "Act," a comprehensive tax reform package representing an overhaul of federal taxation arguably ona level not seen in more than...more
The Tax Cuts and Jobs Act (the "Act") expanded the scope of the $1 million dollar deduction limitation under Section 162(m) of the Internal Revenue Code of 1986, as amended ("Section 162(m)") and, subject to a transition...more
On December 22, 2017, President Trump signed into law a tax bill reconciling both the House and Senate versions of the so-called Tax Cuts and Jobs Act. The Act’s major provisions are lowering the corporate tax rate to 21%...more
On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Act”) into law. While the Act is extensive, this Advisory discusses only the changes made to employee benefits such as qualified retirement plans,...more
Many know that the Section 162(m) deduction limit for performance-based compensation has been repealed by the recent tax legislation together with implementation of other changes, effective for taxable years beginning after...more
The “Bottom Line” - Learn the new rules for who is a “covered employee” and keep track of these individuals because “once a covered employee, always a covered employee” Evaluate compensation arrangements and contracts...more
The Tax Cuts and Jobs Act includes a new provision that can delay the taxation of compensation paid to employees of “eligible corporations” in the form of “qualified stock” for up to five years. The provision is set forth in...more
The Tax Cuts and Jobs Act, signed into law by President Donald J. Trump shortly before Christmas, is the most significant tax reform legislation in more than 30 years. ...more
On December 22, 2017, President Trump signed H.R. 1 (formerly, the “Tax Cuts and Jobs Act” (the “Act”)) into law. While the Act was primarily focused on business tax cuts and individual tax reform, the Act includes several...more