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Tax Reform Taxation

A&O Shearman

Luxembourg introduces tax relief package for corporates and individuals

A&O Shearman on

On July 17, 2024, the Luxembourg Minister of Finance submitted Bill of Law #8414 to the Luxembourg Parliament. The Bill proposes a series of tax measures aiming to make Luxembourg a more attractive place to work, do business...more

Proskauer - Tax Talks

UK government consults on taxation of carried interest

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The newly elected UK Labour government published its call for evidence (see link here) on the taxation of carried interest on Monday 29 July 2024. This consultation by HM Treasury, cautiously anticipated following statements...more

Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

Proskauer - Tax Talks on

On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

Lippes Mathias LLP

Canada’s Capital Gains Tax and the Exodus to the U.S.

Lippes Mathias LLP on

There may be a change coming to the way Canada taxes capital gains. While Prime Minister Justin Trudeau claims it will affect a minuscule percentage of Canadians, it has more than a minuscule percentage of Canadian taxpayers...more

McDermott Will & Emery

Weekly IRS Roundup March 25 – March 29, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25, 2024 – March 29, 2024....more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

McDermott Will & Emery

UK Government Announce Abolition of UK Non-Dom Tax Status and Changes to Come for Inheritance Tax

McDermott Will & Emery on

On 6 March 2024, the UK government announced the planned abolition of the remittance basis of taxation for UK resident non-domiciliaries from 6 April 2025 onwards for foreign income and gains (FIG). This will be replaced with...more

J.S. Held

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

J.S. Held on

The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

McDermott Will & Emery

Italian Tax Reform | Reshoring

McDermott Will & Emery on

On October 16, 2023, the Council of Ministers approved, in preliminary examination, the draft of a legislative decree implementing the tax reform on international taxation. The draft decree must now acquire the opinions of...more

McDermott Will & Emery

Italian Tax Reform: New Residence Definitions for Individuals and Corporations

McDermott Will & Emery on

On October 16, 2023, the Council of Ministers approved, in preliminary examination, the first two drafts of legislative decrees implementing the new “Italian Tax Reform” (Law No. 111/2023). One of these legislative...more

McDermott Will & Emery

Italian Tax Reform

McDermott Will & Emery on

At its meeting on October 16, the Council of Ministers approved, in preliminary consideration, the first two draft legislative decrees implementing the Reform Proxy Law (Law No. 111/2023): – the first legislative decree...more

McDermott Will & Emery

Texas Taxing 130% of Marketplace Sales

McDermott Will & Emery on

Proving that everything is bigger in Texas, the state’s Comptroller is now assessing marketplace providers on 130% of their sales. It seems a sales tax on 100% was not big enough for tax officials in the Lone Star State. The...more

Rivkin Radler LLP

Thomas Paine and Today’s Tax Debates

Rivkin Radler LLP on

Earlier this week, the United States celebrated the 247th anniversary of its declaration of independence from the United Kingdom of Great Britain, though the latter did not formally recognize the independence of its thirteen...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, March 1, 2022

TAX TIDBIT - State of the Union Look Ahead. President Joe Biden will make his first State of the Union address tonight before a joint session of Congress. As of this writing, the speech has not been made available to the...more

Bradley Arant Boult Cummings LLP

Two Important Alabama Tax Bills Cross the Finish Line Midway Through the 2022 Regular Session

The Alabama Legislature has now used 16 of its 30 legislative meeting days so far in the 2022 Regular Session. While the primary focus will be on passing the budgets for the next few weeks, the Legislature has already passed...more

White & Case LLP

Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy: 15% Minimum Tax for...

White & Case LLP on

On November 4, 2021, 137 countries, under the aegis of the OECD, adhered to the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. Pillar 1 aims to ensure a better...more

White & Case LLP

Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy: 15% Minimum Tax for...

White & Case LLP on

On November 4, 2021, 137 countries, under the aegis of the OECD, adhered to the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. Pillar 1 aims to ensure a better...more

Mintz - ML Strategies

House Democrats Weigh Major Tax Changes for Businesses, Funds, and Individuals

Mintz - ML Strategies on

In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...more

McDermott Will & Emery

Weekly IRS Roundup June 14 – June 18, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 14, 2021 – June 18, 2021... June 14, 2021: The IRS issued a news release unveiling updates...more

King & Spalding

Compensation and Benefits Insights - September 2018

King & Spalding on

The IRS recently updated its two model safe harbor explanations that can be used to satisfy the requirement under Section 402(f) to provide notices setting forth certain information to participants who are eligible for...more

Bricker Graydon LLP

Updated IRS rollover distribution notices

Bricker Graydon LLP on

Does your qualified retirement plan pay benefits that may be eligible rollover distributions? The IRS requires employers to provide advance notice to participants of their eligibility to rollover the distribution rather than...more

Cadwalader, Wickersham & Taft LLP

New IRS Guidance Regarding Section 162(m)’s Deduction Limitation for Executive Compensation – Increased Complexity and Reduced...

The Internal Revenue Service (the “IRS”) recently issued Notice 2018-68 (the “Notice”) that provides guidance regarding the application of Section 162(m) of the Internal Revenue Code of 1986, as amended (“Section 162(m)”)...more

Hogan Lovells

IRS issues initial guidance on application of Code Section 162(m) as amended by the Tax Cuts and Jobs Act

Hogan Lovells on

On August 21, the Internal Revenue Service (IRS) issued Notice 2018-68 containing much-awaited interpretive guidance on Section 162(m) of the Internal Revenue Code as amended by last year's tax reform act (Tax Act), including...more

Troutman Pepper

IRS Issues Guidance on Section 162(m) Changes

Troutman Pepper on

On August 21, the IRS issued Notice 2018-68 to provide guidance on changes to Internal Revenue Code Section 162(m), enacted by the Tax Cuts and Jobs Act of 2017 (TCJA). Section 162(m) generally limits the tax deduction...more

Stinson - Benefits Notes Blog

IRS Guidance Provides Some Clarity, but Leaves Questions Unanswered under 162(m)

On August 21, 2018, the IRS issued its initial guidance on the amendments to Section 162(m) made by the Tax Cuts and Jobs Act, in the form of Notice 2018-68. The guidance is fairly limited and does not completely address...more

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