Avoiding Tax Consequences During Oil & Gas Restructurings
On February 4, 2025, and by unanimous vote, the Brazilian Supreme Court’s (STF) Plenary confirmed that the non-levy of ICMS will only apply from the 2024 fiscal year, with the exception of administrative and judicial...more
President Donald Trump made headlines when he announced an External Revenue Service (ERS) agency to collect tariff incomes. The announcement sparked a heated debate among trade experts, economists, and business leaders. But,...more
The UAE government has taken steps to move towards a fully digitized tax system by adopting E-Invoices. The E-invoicing process will be mandatory for all business to business (B2B) and business to government (B2G)...more
President Trump has suggested using tariffs to lower the Federal Government’s reliance on income taxes....more
Cristiano Ronaldo was 2024’s highest-earning Instagram influencer, receiving approximately $3.23 million per post. This jaw-dropping number is not the typical amount that Instagram influencers earn. In fact, on average,...more
On January 16, 2025, the Internal Revenue Service (“IRS”) issued Revenue Ruling 2025-4 (the “Rev. Rul.”). The Rev. Rul. provides guidance on the federal tax treatment of contributions to and benefits paid under a state paid...more
In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...more
Back in November 2023, the Amsterdam High Court ruled that the interest received by X BV (a notary firm) for funds in its trust account qualifies as VAT exempt turnover. According to the High Court, the interest received by X...more
As a Los Angeles-based firm, we are deeply saddened by the devastation caused by the recent wildfires. We remain committed to supporting our clients and friends during this time and are hopeful that the general tax...more
The Michigan Supreme Court released an opinion yesterday holding that a municipality may not disguise a tax by imposing a utilities franchise fee upon consumers through a utilities franchise agreement when that agreement...more
COMPETITION - Compensation for harm caused by a cartel: national legislation preventing a group action for collection may infringe EU law (See CPR No.8/25 - Judgment of the Court in Case C-253/23, ASG 2)....more
Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more
On 1/21/25, the IRS issued Bulletin Issue Number: 2025-02 to remind the FATCA Responsible Officer that Certifications are due 7/1/25 for the Certification period ending December 31, 2024. The Bulletin also provided a...more
On January 8, 2025, the staff (Staff) of the Securities and Exchange Commission’s (SEC) Division of Investment Management (IM) released the 2025 Names Rule FAQs (2025 FAQs) related to the amendment of Rule 35d-1 (Names Rule)...more
On 1/15/25, the IRS announced three pilot programs to test changes to existing Alternative Dispute Resolution (ADR) programs. The new IRS Pilot Mediation Programs are designed to help taxpayers resolve tax disputes earlier...more
Recent and prospective political developments in Canada, including the prorogation of Parliament and a possible dissolution of Parliament in the winter or spring of 2025, have important consequences for Government of Canada...more
Setting up operations in the Middle East comes with a unique set of challenges and considerations requiring knowledge of regional legal obligations and cultural practices that can affect workplaces—from the necessity of...more
On December 27, 2024, the Treasury and the IRS released final regulations (the “Final Regulations”) on reporting requirements for decentralized finance (“DeFi”) participants, accompanied by a press release, and Notice 2025-3,...more
On Monday, President Trump followed through on his promise to sign nearly 100 executive orders on topics ranging from energy and the economy to border security, federal workforce reforms and a host of social issues discussed...more
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more
Fueron publicadas en el Diario Oficial de la Federación (DOF) el 30 de diciembre de 2024, la versión de las nuevas Reglas Generales de Comercio Exterior (RGCE), las cuales entraron en vigor el 1 de enero de 2025 en México....more
As Maryland’s 477th legislative session quickly approaches, and with a $2.9 billion budget shortfall looming, lawmakers will have to make tough decisions to address the state’s largest budget shortfall since the Great...more
On December 30, 2024, the Department of the Treasury (the Treasury) and the Internal Revenue Service (the IRS) published the final regulations (Final DeFi Regulations) relating primarily to persons who are front-end service...more
Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more
The global tax landscape is experiencing a profound transformation as the OECD/G20’s Pillar Two rules are adopted. Among these, the Undertaxed Profits Rule (UTPR) has emerged as a pivotal mechanism designed to ensure that...more