The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax
Employee Benefits and Executive Compensation: Getting Ready for 2024 - Qualified Plans — Special Edition Podcast
End of Year Tax Planning: Tips for Healthcare Professionals and Practices
Change of Control: Golden Parachute Rules in the Sale Process
4 Key Takeaways | Mid-Year Tax Update
TELL ME SOMETHING GOOD! Planning for Post-Retirement Medical Expenses with 401(h) Plans
TELL ME SOMETHING GOOD! Planning for Post-Retirement Medical Expenses With 401(h) Plans
NOWOTNY KNOWS SQUAT! Part IV Using Post-Retirement Medical Plans to Raise AUM and Sell Life Insurance
NOWOTNY ON DEATH AND TAXES EPISODE 35 USING POST-RETIREMENT MEDICAL PLANS TO RAISE AUM
COVID-19 Relief in 2021: What Small Businesses Need to Know
The Biden Tax Plan
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!
KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!
The Freeman Law Project – Episode 21 – The New York Times and President Trump's Taxes
ROCK OF AGES video
On-Demand Webinar | PPP Loan Forgiveness: Employment and Tax Issues for Borrowers
THE SPLIT DOLLARMINATOR!
The Department of Finance (Canada) (Finance) has released revised draft legislation on the proposed rules regarding excessive interest and financing expenses limitation (EIFEL). The revised draft legislation, released on...more
Here's a summary of the new tax provisions in the Build Back Better Act proposed by the Senate Finance Committee, as compared to the version that the House passed on November 19, 2021....more
On December 27, 2020, President Trump signed into law the Consolidated Appropriations Act, 2021 (the “Act”). The Act enhances and expands certain provisions of the Coronavirus Aid, Relief, and Economic Security Act (the...more
Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more
The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more
The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18 – 22, 2019. November 19, 2019: The IRS published final regulations that affect United...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...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
Many New Jersey taxpayers have a reason to celebrate today as the Division of Taxation withdrew Technical Bulletin-85, providing for a special apportionment regime for global intangible low-taxed income (GILTI) and income...more
Eighteen months after the passage of the Tax Cuts and Jobs Act (TCJA or the Act), tax practitioners and taxpayers alike still are looking to Treasury for guidance to interpret and fill in gaps in the new tax laws. The hasty...more
Tax structuring under the previous regime - Prior to the issuance of the final regulations described below, under Section 956 of the Internal Revenue Code of 1986 and its related Treasury Regulations, for U.S. tax...more
On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more
Until recently, the structuring of debt facilities for U.S. borrowers with foreign subsidiaries has been largely driven by IRS interpretations of section 956 of the Internal Revenue Code, which gave rise to significant tax...more
2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more
On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law 115-97, the Tax Cuts and Jobs Act (TCJA), amended Internal Revenue Code (Code)...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more
On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more
Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more
Following tax reform at the end of 2017, cash dividends from a foreign corporate subsidiary to a domestic corporate 10 percent shareholder are exempt from U.S. income tax because the shareholder is permitted a...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2018 on 29 October 2018. The Budget was delivered against the backdrop of the UK’s negotiations with the European Union concerning Brexit. ...more
Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI). - The Section 250 deduction - The renewed importance of Section 962 - Beware of...more
The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...more