Nonprofit Quick Tip: State Filings in Massachusetts and Connecticut
EV Tech Series: The Inflation Reduction Act’s Impact on the Energy Industry With Judy Kwok and Marc Machlin - Battery + Storage Podcast
Tribal Tax Exemption Under McGirt Gains Preliminary Victory
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
ATTENTION ALL CADETS!
One Note Samba
Podcast: State Taxation of Digital Health Products
Investment Management Roundtable Discussion – Personal Estate Planning
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Episode 26: Talking Tax Reform and Executive Comp
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
New York Estate Tax Law Changes
Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more
It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more
1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more
The 2021 Italian Budget Law aligns the tax treatment applicable to EU investment funds with the tax treatment applicable to Italian investment funds....more
On February 26, 2019 the Court of Justice of the European Union (CJEU) issued the long-awaited judgments on the cases concerning the Danish government withholding tax on dividends and interest paid by Danish companies to...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
Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations thereunder, deemed dividends were potentially created when a U.S. borrower...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 “deemed dividend” rule, the source of much wrangling between multi-national borrowers and lenders over the years, may be on its way out....more
On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more
• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more
The French Finance Act for 2016 and Amending Finance Act for 2015 were enacted on December 30, 2015 (the “Acts”). Under the new legislation, the neutralization of the 5% add-backs on dividends within tax-consolidated groups...more
As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more
Reform of taxation of free floating dividends for corporate income tax purposes The German Parliament (Bundestag) and the German Federal Council (Bundesrat) reached an agreement regarding the taxation of free floating...more
Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more
As part of legislation enacted in early 2013 to avert the so-called “fiscal cliff,” Congress temporarily extended several beneficial tax provisions for businesses, including the research credit, the active financing exception...more
On New Year’s Day 2013, the “American Taxpayer Relief Act of 2012” (the Act) was enacted to avoid the impact of automatic “fiscal cliff” tax increases. The Act, effective January 1, 2013, retains and makes permanent the...more
In the final hour of January 1, 2013, Congress passed The American Taxpayer Relief Act of 2012 (the "Act"), which in part addressed the dramatic sunset of favorable federal estate, gift and generation-skipping tax exemption...more