News & Analysis as of

Internal Revenue Code (IRC) Federal Taxes Tax Reform

Cooley LLP

Proposed Federal Tax Legislation Would Effect Three Key Changes to State and Local Tax Deductibility Limits

Cooley LLP on

On May 22, the House of Representatives passed proposed tax legislation titled, “The One, Big, Beautiful Bill” (TOBBB), which will now be debated in the Senate. Among other proposals, if enacted into law, TOBBB would make...more

Davis Wright Tremaine LLP

Watch the Sunset: Federal Estate Exclusion Set To Shrink in 2026; New Changes on the Horizon

The 2017 Tax Cuts and Jobs Act (TCJA) is set to end at the close of this year, resulting in a federal estate exclusion that is less than half of the current $13.99 million exclusion. Other changes to the tax structure are...more

Rivkin Radler LLP

Will the Federal Estate and Gift Tax Exemption Be Reduced in 2026?

Rivkin Radler LLP on

The federal estate and gift tax exemption changes from year to year. The current combined federal estate and gift tax exemption amount of $13.99 million per person ($27.98 million per married couple) is scheduled to “sunset”...more

McDermott Will & Emery

Weekly IRS Roundup November 6 – November 10, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 6, 2023 – November 10, 2023...more

McDermott Will & Emery

Weekly IRS Roundup December 12 – December 16, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 12, 2022 – December 16, 2022...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...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

Goodwin

U.S. House Proposals Would Significantly Impact Estate Planning for High Net Worth Individuals If Enacted

Goodwin on

The U.S. House Committee on Ways and Means’ tax proposals would significantly impact estate planning for high net worth individuals if enacted. Gift, estate and GST exemption amounts would be decreased; grantor trusts would...more

Morrison & Foerster LLP

New Section 956 Regulations Expand Scope of the New Participation Exemption But May Expose Borrowers to Increased Collateral...

Morrison & Foerster LLP on

On October 31, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations that would limit the application of Section 956 of the Internal Revenue Code (the “Code”) in an attempt to align it...more

Bradley Arant Boult Cummings LLP

Three Things You Need to Know: How Trump’s “Tax Cuts and Jobs Act” Will Impact State Incentives and Project Recruitment - Economic...

As you may know, President Trump signed into law the Tax Cuts and Jobs Act (TCJA), enacting broad reforms to the Internal Revenue Code. How your state implements these reforms may have an impact on project recruitment and...more

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

Vedder Price

Tax Reform’s Impact on Transportation Finance Transactions

Vedder Price on

New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

McDermott Will & Emery

Finishing SALT: May State Focus & April Wrap-Up

A Grain of SALT: May State Focus – Georgia - Georgia was one of the first states to enact comprehensive legislation in response to the federal tax reform bill, known as the Tax Cuts and Jobs Act (TCJA). As a preliminary...more

McDermott Will & Emery

New Mexico Administrative Hearings Office Issues Timely Opinion Regarding State Taxation of Subpart F Income and Dividends from...

McDermott Will & Emery on

Earlier this month, the New Mexico Administrative Hearings Office issued an opinion that addressed the questions on the minds of many state tax professionals in the wake of federal tax reform: under what circumstances can a...more

Skadden, Arps, Slate, Meagher & Flom LLP

New York State Responds to Federal Tax Reform

On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more

McDermott Will & Emery

Overview of Minnesota’s Response to Federal Tax Reform

McDermott Will & Emery on

Minnesota has several bills pending that would address the Minnesota state tax implications of various provisions of the federal tax reform legislation (commonly referred to as the Tax Cuts and Jobs Act)....more

McDermott Will & Emery

Illinois Confirms Treatment of Deemed Repatriated Foreign Earnings Provisions

McDermott Will & Emery on

On Wednesday, the Illinois Department of Revenue (Department) issued additional guidance concerning its treatment of the new deemed repatriated foreign earnings provisions found in Internal Revenue Code Section 965, enacted...more

Morgan Lewis

State Tax Implications of Federal Tax Changes to Section 162(m)

Morgan Lewis on

Due to the varying methods of state conformity to the Internal Revenue Code, both the prior and current versions of Section 162(m) continue to be a consideration for state taxes....more

McDermott Will & Emery

Southeast States Respond to Federal Tax Reform and NJ Senate Leader Talks Tax Surcharge to Limit Corporate “Windfall”

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Virginia and Georgia are two of the latest states to pass laws responding to the federal tax reform passed in December 2017, known as the Tax Cuts and Jobs Act (TCJA). Both states updated their codes to conform to the current...more

McDermott Will & Emery

Illinois Responds to Federal Tax Reform Bill by Proposing Legislation to Decouple from the FDII Deduction

The 2017 federal tax reform bill, known as the Tax Cuts and Jobs Act (Act), made a number of significant changes to the law, particularly to the international tax provisions of the Internal Revenue Code (IRC). Last month,...more

McDermott Will & Emery

Governor Cuomo’s Amended Budget Bill Would Address the Deemed Repatriation Dividend Provisions

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New York is the latest state to address certain state tax implications of the 2017 federal tax reform bill, the Tax Cuts and Jobs Act. Governor Andrew Cuomo’s 30-day amendments to the Governor’s Budget Bill were released on...more

McDermott Will & Emery

Connecticut Responds to the Federal Repatriation Tax

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Earlier this month, Connecticut Governor Dan Malloy released his Governor’s Bill addressing the various state tax implications of the federal tax reform bill enacted by Congress in December 2017, commonly referred to as the...more

Akin Gump Strauss Hauer & Feld LLP

Dramatic Change to Federal Estate, Gift and Generation-Skipping Tax Exemptions

• Each individual’s exemptions from federal estate, gift and GST taxes have roughly doubled to approximately $11,200,000 • The increased exemptions are available only temporarily, through 2025 • We recommend that you...more

McDermott Will & Emery

SALT Implications of Final Section 385 Debt-Equity Regulations

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The recently released final regulations under Internal Revenue Code Section 385, addressing the circumstances under which related company debt will be classified as equity for federal income tax purposes, will have a...more

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