Avoiding Tax Consequences During Oil & Gas Restructurings
Double taxation arises when the same income is taxed in two different jurisdictions, potentially leading to excessive tax burdens for individuals and businesses. The UAE has developed a comprehensive legal framework to...more
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
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
On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more
This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
On April 26, 2024, IRS Chief Counsel, Income Tax & Accounting (IT&A), released a legal memorandum (ILM) addressing the treatment of credit card reward liabilities for which a customer earns rewards that can be redeemed for...more
Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more
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
On March 6, 2024 UK Chancellor Jeremy Hunt announced in his Spring Budget an intention to rewrite the UK taxation of internationally mobile people from April 2025. As outlined it would appear to be a zero tax regime on non-UK...more
What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how...more
Unless you have been living under a rock—as we tax lawyers are wont to do—you have probably been following Moore v. United States, which we last discussed. On December 5, the tax community stepped into the spotlight...more
Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 13, 2023 – November 17, 2023. ...more
Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more
Was your community association lucky enough to come in under budget last year? On the surface, this might appear to be a bonus, but if not handled properly, it can quickly turn into an unexpected tax burden. ...more
Approaching Year End- Which holiday do you dread the most? For me, it has always been, and likely will always be, Labor Day. Of course, with each passing year, anything that I describe as “always” is less meaningful than...more
On August 9, 2023, the New York State Department of Taxation and Finance (Department) released 417 pages of proposed regulations, an important step toward concluding a now almost decade-long process to implement corporate tax...more
Hasta La Vista N.Y.- Wealthy individuals continue to leave New York for tax friendlier jurisdictions. Be Prepared- Some of these taxpayers take a very methodical approach toward planning for their departure. They...more
Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more
Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more
I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more
El Formulario 1040 2022 cambia la terminología criptográfica de “moneda virtual” a “activos digitales”. El propósito del cambio en la terminología podría interpretarse como un “aviso” a los contribuyentes de que el IRS está...more
The cryptocurrency market was down approximately 64% for the year 2022, with most of the decline occurring before the FTX collapse. For many, this news may bring a feeling of JOMO (Joy of Missing Out). For practitioners...more
The Department for International Tax Co-operation (DITC) issued a revised version (version 3.2) of the Guidance on Economic Substance For Geographically Mobile Activities in July 2022 (Revised ES Guidance Notes)....more
On June 9, 2022, the Internal Revenue Service issued Announcement 2022-13, increasing the optional standard mileage rate for the final six months of 2022 from 58.5 cents per mile to 62.5 cents per mile. The new rate will be...more