Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
Musings on Multinational Tax: What to Expect From GILTI Conscience
4 Key Takeaways | Mid-Year Tax Update
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
III-39 - 2nd Anniversary Special Episode
Qualified Opportunity Zone Fund Investments
[WEBINAR] Labor & Employment Law: What Changed in 2017
Impact of Tax Reform on Charitable Giving
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Life Sciences Quarterly: Tax Cuts and Jobs Act: Implications for Life Science Business
Private equity investments
II-27 - Our 1st Anniversary Special: Bringing Back Our Inaugural Guest to Discuss What Was and What Will Still Be With President Trump
II-26 – Superbowl Concerns, Tax Reform/MeToo, Restrictive Covenant Crimes, and Expanded Religious Discrimination Theories
II-25 – Top 10 New Year’s Resolutions for Employers in 2018
How Will the New Tax Reform Bill Affect You?
In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more
Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more
Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more
On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...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
Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more
UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more
On January 27, 2022, Supreme Court of the United States Justice Stephen Breyer formally announced his retirement, effective when the Supreme Court breaks for summer recess in June or July later this year—after his successor...more
TRANSACTION PRIVILEGE TAX UPDATES LEGISLATION - Senate Bill 1110, Chapter 443. Tribal Exemptions. This bill codified the following exemptions applicable to Indian tribes and tribal members at A.R.S. § 42-5121 et seq.: (1)...more
UK Case Law Developments - Taxpayer treated as receiving distribution in tax avoidance case - We reported on First-tier Tribunal’s (FTT’s) decision in Dunsby v Revenue & Customs in our June 2020 UK Tax Round Up. By way...more
Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s...more
Many states and localities give incentives for business to move or transact in their locations. There has always been a question of whether these incentives are taxable income under federal income tax law. Internal Revenue...more
Thanksgiving, 2018 – Bucks County, Pa. - A Brief Look Back - I always know summer is over when I sit down to draft our annual Year-End Tax Update because the leaves are brown, the sky is gray, Rita’s water ice shop is...more
On December 20, 2017, Congress passed the “Tax Cut and Jobs Act,” which was signed into law by President Trump on December 22, 2017. With some exceptions, the law’s provisions generally are effective for tax years beginning...more
The fourth quarter of 2017 concludes a unique year in the planning arena. With the new administration and a Republican-led Congress in power, both taxpayers and tax professionals have kept a close eye on the potential for tax...more
Following the inauguration of the new administration in January 2017, many investors were anticipating the passage of a transformative tax reform bill at some point in 2017. Although legislative tax reform is seemingly...more
In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more
Retroactive Application Of 2010 Statutory Amendment Permitted By Tribunal - Reversing the decision of an Administrative Law Judge, the New York State Tax Appeals Tribunal has upheld the constitutionality of retroactively...more
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
Court Of Appeals Affirms Revocation Of Tax Exemption For Public Parking Facilities - Reversing a decision by the Appellate Division, the Court of Appeals has held in a 5-2 decision that a charitable organization is not...more
IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more