News & Analysis as of

Internal Revenue Code (IRC) Tax Rates

Davis Wright Tremaine LLP

House GOP Tax Proposal Targets Nonprofits

On May 12, 2025, the House Ways and Means Committee released a draft version of the Republican-led tax bill, "The One, Big, Beautiful Bill" (the "Bill"), which is designed to advance President Trump's tax reform agenda. The...more

A&O Shearman

House Ways and Means Committee releases draft tax amendments for 2025 Reconciliation Bill

A&O Shearman on

On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more

Proskauer Rose LLP

Wealth Management Update - February 2025

Proskauer Rose LLP on

February 2025 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February applicable federal rate (“AFR”) for use with a sale to a defective grantor...more

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Proskauer - Tax Talks

Tax Proposals Potentially Being Considered by the U.S. House Budget Committee in Reconciliation

Proskauer - Tax Talks on

On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing...more

Foster Garvey PC

A Birthday Greeting to the Tax Reform Act of 1986

Foster Garvey PC on

The Tax Reform Act of 1986 (the “TRA 86”) was signed into law by President Ronald Reagan on October 22, 1986, exactly 38 years ago today. TRA 86 was sponsored by, among others, Representative Richard Gephardt (D-Missouri) in...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman David Schweikert, R-AZ

BakerHostetler on

Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy and political debates in Congress. In this episode of “The Cloakroom with...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman Brendan Boyle, D-PA

BakerHostetler on

Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy debates in Congress. In this episode of “The Cloakroom with Peter Roskam,”...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part VII –...

Foster Garvey PC on

In the S corporation arena, tax advisors generally do not focus much attention on unreasonable compensation. As we delve into the issue in this Part VII of my multi-part series on Subchapter S, it will become apparent that...more

ASKramer Law

Taxation of Foreign Currency Transactions Part II: Gains, Losses, Personal Transactions, and Electing Out of Section 988

ASKramer Law on

Are all foreign currency gains taxable? No. Under a de minimis exemption individual taxpayers with foreign currency gains of $200 or less on a “personal transaction” do not need to report them....more

DarrowEverett LLP

Maximizing QSBS Benefits with Estate Planning: The Art of Stacking

DarrowEverett LLP on

The number of taxpayers seeking the benefits of Qualified Small Business Stock (“QSBS”) has picked up steam in recent years, particularly since the Tax Cuts and Jobs Act (“TCJA”) lowered the federal corporate tax rates to...more

ASKramer Law

Taxation of Foreign Currency Transactions Part I: Definitions and Rules for Taxing Foreign Currencies

ASKramer Law on

Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more

DarrowEverett LLP

Accidental Termination on Purpose? S Corp Ruling Could Be Huge For QSBS Owners

DarrowEverett LLP on

Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...more

McDermott Will & Emery

TTB Ramps Up Tax Audits and Enforcement

McDermott Will & Emery on

The Alcohol and Tobacco Tax and Trade Bureau’s (TTB) Office of Field Operations is responsible for ensuring industry members comply with the Federal Alcohol Administration Act, the Internal Revenue Code and all related...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part II – Code...

Foster Garvey PC on

This second installment of my multi-part series on Subchapter S is focused on two Code Sections, namely IRC Section 1375 and IRC Section 1362(d)(3)....more

Rivkin Radler LLP

Nothing Lasts Forever –Expiring Tax Provisions

Rivkin Radler LLP on

The Long-Term View- Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole. ...more

Allen Barron, Inc.

The High IRS Tax Rates on a Foreign Trust

Allen Barron, Inc. on

Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more

Holland & Knight LLP

Condemned to Lose Your ADIT?

Holland & Knight LLP on

In a private letter ruling, the IRS concluded that the condemnation of public utility property is in effect a "retirement" or "disposition" that requires the elimination of accumulated deferred income taxes (ADIT) associated...more

Goulston & Storrs PC

Biden’s FY2024 Budget: Key Real Estate Tax Proposals

Goulston & Storrs PC on

On March 9, 2023, President Biden released his FY2024 budget (the “FY2024 Budget”), and the U.S. Treasury released the so-called “Green Book," which provides details related to the revenue provisions in the FY2024 Budget....more

Pierce Atwood LLP

2023 Federal and State Estate and Gift Tax Summary

Pierce Atwood LLP on

Estate and gift taxes are levied on transfers of property during lifetime and at death. The federal government and many state governments impose such taxes and adjust the amounts subject to tax annually for inflation (or...more

Burr & Forman

Changes in Tax Rates for 2023

Burr & Forman on

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

McDermott Will & Emery

Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

Cadwalader, Wickersham & Taft LLP

Looking Forward: The IRS Denies 40/60 Treatment for Over-the-Counter Foreign Currency Options under the Mark-to-Market Rules

The IRS has published Proposed Regulations clarifying that for purposes of the mark-to-market rules under section 1256, foreign currency contracts include only foreign currency forward contracts, and that the definition does...more

Groom Law Group, Chartered

Administration Budget Proposals Tighten Rules for 409A Violations, VEBA Funding and Indemnity Health Plans

On March 28, the Biden Administration submitted its Fiscal Year 2023 budget proposals reflecting its budget and tax policy priorities, which could surface when Congress resumes work on budget reconciliation. While it is...more

Freeman Law

Tax Treaty-Based Return Reporting Disclosures

Freeman Law on

A taxpayer taking a treaty-based return position is generally required to disclose that position, unless an exception applies. A treaty-based return position is a tax reporting position, maintaining that a U.S. tax treaty...more

114 Results
 / 
View per page
Page: of 5

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide