Stoel Rives | Deeply Rooted Podcast Episode Four: The Financialization of Agriculture with David Muth from Alternative Equity Advisors
Adult-Use Marijuana Legalization in NYS – What You Need to Know
On Monday, September 9, 2024, the California FTB approved proposed amendments to California’s personal income tax code. This proposed rule would impose California income tax on non-resident/non-employee corporate...more
Brownstein was privileged to sponsor this year’s Rockies Petroleum Conference, hosted by the Petroleum Association of Wyoming, in Laramie, Wyoming, on Aug. 21–23, 2024....more
The Texas Tax Code has an oft-overlooked provision that imposes harsh penalties against financial institutions that fail to strictly comply with a notice of freeze or levy issued by the Office of the Texas Comptroller against...more
In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more
The United Kingdom (“UK”) has specific corporate tax rules on the taxation of loan relationships (parts 5 and 6 of the Corporation Tax Act 2009 (the “Loan Relationships Regime”)). The Loan Relationships Regime contains rules...more
The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more
As the 2024 general election draws near, one of the central issues capturing the attention of voters and lawmakers alike is the future of tax policy. With the two presidential candidates offering a range of proposals and...more
Generally, in Ohio, sales of tangible property are taxable unless an exemption exists, whereas services are generally nontaxable unless specifically enumerated as taxable under the Ohio Revised Code. However, Ohio has many...more
Navigating International Estate Planning - Today, more and more people own property in more than one country, and that requires particular consideration when planning their estate. Traveling has become so easy that many...more
The 2024 Paris Olympics are in full swing, and it is never too early for U.S. athletes to consult with their tax advisor. As was done in 2021, the United States Olympic & Paralympic Committee has pledged to award U.S....more
We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and...more
The idea of student loan forgiveness has caught the attention of many borrowers and sparked lots of discussions. If you're wondering how this might affect your taxes, you're not alone. It's important to know the rules and...more
In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT), saving a significant portion of the current tax code for now. The question in front of the Court was whether...more
In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...more
To generate revenue, increase enforcement resources, and “crack down on tax fraudsters,” the District of Columbia amended its False Claims Act (DC FCA) in 2021 to expressly impose liability arising from DC tax code...more
This article is the second in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees?...more
Proponents and opponents of proposed “wealth tax” legislation alike watched the Supreme Court carefully as it heard oral arguments for, and subsequently decided Moore v. United States on June 20, 2024. The crux of the Moores’...more
As a general rule, when a married couple files a joint tax return, they are jointly and severally liable for the entire tax. But what happens if one spouse failed to report income and the other spouse did not know or have...more
Based on the 1978 voter initiative commonly referred to as “Proposition 13,” the government can reassess the value of real property for taxation purposes after a “change in ownership” of the property. The meaning of “change...more
Extemporaneously Cancelled Invoices Can Be Given Tax Effect - Through an amendment made to article 29-A of the Mexican Federal Tax Code (Código Fiscal de la Federación or CFF), since 2022 the period during which taxpayers...more
In 2016, Italy introduced a new form of security on moveable goods, which does not require the debtor to surrender the goods to the creditor or a custodian. Instead, it requires the pledgor to register the goods in a digital...more
In Ohio, sales of tangible personal property are presumed taxable unless an exemption exists. On the other hand, services are presumed nontaxable unless specifically enumerated as taxable under Ohio’s Revised Code. Many of...more
As noted in our prior advisory, U.S. citizens and residents who receive gifts exceeding certain thresholds from foreign persons must generally report such gifts to the IRS on Form 3520, and the IRS does not hesitate to impose...more
The Texas Tax Code provides that, as a general matter, Texas sales and use tax are imposed on sales of “tangible personal property” or “taxable services.” However, various exemptions apply to these items to provide relief to...more
What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more