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
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
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 Italian government recently approved a draft 2024 budget law which provides for the extension of the domestic participation exemption regime on disposal of shareholdings (PEX) to those non-resident corporations that: (i)...more
Before founders can kick-start operations, bring in customers, or engage investors, they are advised to create a legal entity to pursue such milestones. Establishing a legal entity serves several key purposes: the founder can...more
En Oficio #1356 del 9 de noviembre de 2022, la Dirección de Impuestos y Aduanas Nacionales (DIAN) señaló que la integración en Colombia de dos sucursales de sociedades extranjeras, como resultado de una fusión entre sus dos...more
For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living. And in an increasingly global...more
Transactions within a corporate group can sometimes achieve reduction of tax obligations, regardless of whether or how much such result was intended. One typical way observed is to extend an international intra-group loan by...more
Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more
Congress recently returned from its two-week recess with an extensive to-do list. Between now and the August recess, the House will be in session for a total of 32 legislative days, and the Senate will be in for 54...more
Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more
On Monday, Sept. 13, House Ways and Means Committee Chair Richard Neal (D-MA) introduced the final portion of the committee’s budget reconciliation recommendations. This alert provides a comprehensive summary and analysis of...more
The State of Arizona adopted several significant tax measures during the 2021 legislative session, including an individual income flat tax, a high-earner tax bypass, and a federal SALT cap workaround. Background - ...more
A corporate client of the firm was recently sued for breach of contract and other violations. However, the company manager found himself facing a personal liability allegation for the company debts....more
New York’s Governor Cuomo is having a bad 2021. Some may attribute this to his hubris or to karma; others may point to an emboldened, and now veto-proof, progressive State Legislature; many will claim that Mr. Cuomo is paying...more
During the run-up to the November presidential election, then-candidate Joe Biden previewed his tax priorities to enact a more progressive tax code to roll back "giveaways" to wealthy individuals and corporations under the...more
In my practice, I have seen various issues related to a taxpayer’s S election. Corporations potentially jeopardize their S election by unknowingly creating a second class of stock through convertible debt. Corporations,...more
The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more
A corporation may not deduct previously capitalized costs that facilitated an initial public offering (IPO) even when it later ceases to be a publicly traded company, according to an internal memorandum by the Internal...more
Outsourcing or co-sourcing tax functions can offer both qualitative and quantitative benefits so tax departments can focus on other areas that may be more beneficial for a company. ...more
This Alert summarizes the more significant tax provisions enacted by the North Carolina General Assembly in 2019. The most important tax changes were originally included in House Bill 966, the 2019 Appropriations Act (the...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
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more
In a special session, the Maine legislature passed tax conformity legislation on August 30, 2018, after having failed to pass this legislation prior to its spring adjournment. The legislation is now on the Governor’s desk...more
On December 20, 2017, Congress passed the most extensive package of reforms to the United States income tax system since the overhaul of the tax code in 1986. Enacting tax reform has been a key priority of the Trump...more
On Wednesday, Dec. 20, 2017, Congress passed a sweeping $1.5 trillion tax reform of the Internal Revenue Code of 1986. Dubbed the “Tax Cuts and Jobs Act,” the bill next heads to the President’s desk to be signed into law,...more