News & Analysis as of

Tax Liability Internal Revenue Service Tax Cuts and Jobs Act

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

BakerHostetler

[Podcast] Implications of Supreme Court’s Tax Decision in Moore v. United States

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A team of BakerHostetler lawyers, led by Partners Andrew Grossman and Jeff Paravano, represented clients Charles and Kathleen Moore at the Supreme Court, arguing that realization is required for federal taxation of income...more

Holland & Knight LLP

Moore Thoughts: An Incremental Opinion from the U.S. Supreme Court

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The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more

Eversheds Sutherland (US) LLP

Doing less with Moore: Supreme Court upholds section 965 transition tax in Moore v. United States

Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more

Morgan Lewis

Biden Highlights IRS Plans to Audit Corporate/Partnership Jet Use in State of the Union Address

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In his State of the Union address, President Joseph Biden targeted tax breaks for corporations and wealthy individuals who use private jets as part of a broader goal to make big corporations and the wealthy pay “their fair...more

Kohrman Jackson & Krantz LLP

Scrutiny on Personal Use of Business Jets Intensifies: IRS to Conduct Audits

Initially, tracking systems were employed to monitor the private jet usage of celebrities like Taylor Swift. Now, similar scrutiny will extend to executives who utilize business aircraft for personal purposes while claiming...more

Cadwalader, Wickersham & Taft LLP

Eager for Moore?

On December 5, the Supreme Court heard oral arguments on Moore v. United States, which is potentially the next landmark tax case on the meaning of income under the Sixteenth Amendment....more

Kohrman Jackson & Krantz LLP

IRS Increases 2024 Federal Estate Tax Exemption and Gift Tax Exclusions: Key Points for Taxpayers

Estate planning is a lot like putting together a puzzle. The client provides you with their box lid showing what they want the ultimate result of their plan to look like. Then, estate planners are tasked to identify and...more

Freeman Law

Section 965 Tax Installment Payments Are Not Guaranteed

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The Section 965 transition tax. Taxpayers with international earnings are still grappling with their reporting and payment obligations under the “deemed repatriation” tax after its enactment by the Tax Cuts and Jobs Act of...more

Freeman Law

Tax Court in Brief | Rojas v. Commissioner | Deduction of Alimony and Child Support Under IRC Section 215

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Tax Litigation: The Week of July 18th, 2022, through July 22nd, 2022 Pettennude v. Comm’r, T.C. Memo. 2022-79 | July 18, 2022 | Buch, J. | Dkt. No. 636-21L Gonzalez v. Comm’r, T.C. Summary Opinion 2022-13 | July 18, 2022 |...more

Jones Day

IRS Targeting Noncompliant Qualified Opportunity Funds and Their Investors

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On April 12, 2022, the Internal Revenue Service announced that starting this month, it will send letters to taxpayers requesting that they take corrective actions related to the reporting of investments in qualified...more

Freeman Law

Final Regulations on Stock Owned by Domestic Partnerships under Subpart F

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On January 25, 2022, the Internal Revenue Services issued final regulations relating to the treatment of stock owned by domestic partnerships under certain provisions of subpart F of the Internal Revenue Code (“Subpart F”). ...more

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

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While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

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Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Akin Gump Strauss Hauer & Feld LLP

Secondary U.S. Withholding for Transfers in Private Investment Funds Delayed Until January 1, 2023

Key Points - Fund-level liability for a buyer’s failure to withhold upon secondary market transfer of an LP interest in a fund with ECI assets will apply only for transfers on or after January 1, 2023. Certain...more

Rivkin Radler LLP

The President’s Recent Tax Proposals: What Do They Mean For Business Owners?

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A Night to Remember? Did you listen to the President’s speech last Wednesday? He addressed a joint session of Congress to pitch the Administration’s $1.8 trillion American Families Plan. Due to COVID-related...more

Polsinelli

No S-Corp for You? – New Proposed Carried Interest Regulations that May Affect Crypto Fund Managers

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Historically, the ability for investment fund managers to take profits in the form of carried interest has allowed those managers to pay the lower long-term capital gains tax rate (compared to income) so long as the...more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

Proskauer - Not for Profit/Exempt...

Repeal of Unrelated Business Income Tax on Qualified Transportation Fringe Benefits

Late on Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax.”...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

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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

Cozen O'Connor

The Deductibility of Future Alimony Payments Just Might Depend on the Past

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The Tax Cuts & Jobs Act of 2017 eliminated the tax deduction previously allowed for alimony payments effective January 1, 2019.  This meant that alimony payments made pursuant to an agreement executed after December 31, 2018...more

Chambliss, Bahner & Stophel, P.C.

Kiddie Tax Changes May Increase Burden for Families with SNTs

Major changes to the “kiddie tax” could significantly increase the tax liability of assets placed in special needs trusts if the trust’s beneficiary is a minor and the income the trust earns is high enough. Congress...more

Troutman Pepper

Transferring Partnership Interests: Buyer Beware of Withholding Obligations, Seller Beware of Tax Liability - Tax Update Volume...

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The U.S. federal taxation of non-U.S. persons who transfer interests in partnerships has a long and storied history. The government staked out its position in 1991, effectively providing that a non-U.S. partner should be...more

McDermott Will & Emery

Weekly IRS Roundup February 25 – March 1, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05,...more

Foodman CPAs & Advisors

IRS Guidance on Business Meals is Transitional

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The Tax Cut and Jobs Act (TCJA) amended Section 274 of the Internal Revenue Code (IRC) created a confusion for Taxpayers by disallowing a deduction for expenses with respect to “entertainment”, amusement, or recreation and...more

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