REFRESH: Loot and Private Foundation Rules – Part 2
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Candidate Campaign Intervention
Domestic Tax Planning - Podcast with Janathan Allen
Tax Liability Insurance Products: A Hidden Gem in the Transactional Lawyer’s Tool Box
JONES DAY PRESENTS®: Tax Implications of Telehealth as Remote Services Become Norm
Podcast: Got Mail? What to Do When the IRS Contacts You [More with McGlinchey, Ep. 42]
Tax Legend Fred Goldberg Shares Insights From His 50 Years in Tax Law
Let's Talk What to Bring to Your First Family Law Appointment
The Renoir Spelling Bee
Eastward Bound: Cannabis Market Trends, Taxation, and More
Why Cannabis Related Businesses Must Consider Legal and Tax Issues
2021 House Ways And Means Tax Proposals
Coronavirus in the Workplace
How are Your Company’s Taxes Impacted by the New U.S. DOL Rule on Independent Contractors?
KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!
The Chancellor of the Exchequer, Rachel Reeves MP, presented her first Budget to Parliament on 30 October 2024. In it, she announced both tax rate increases and also proposals which would fundamentally change the tax...more
Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more
Dans une décision rendue le 6 septembre 2024, la Cour du Québec (la « Cour »), sous la plume de l’honorable Daniel Bourgeois, a statué que la déduction pour créance irrécouvrable dans le calcul de la taxe nette et prévue à...more
In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more
In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more
In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more
The Federal Cabinet adopted the government draft of an Annual Tax Act 2024 (JStG 2024) on June 5, 2024. The government draft largely corresponds to the draft bill of May 17, 2024 and contains a large number of very different...more
The Tax Cuts and Jobs Act of 2017 amended the law to introduce a new, one-time, mandatory repatriation tax on trillions of dollars of accumulations held abroad by American-controlled foreign entities. The tax is imposed on...more
In a blog post on May 21, 2024, National Taxpayer Advocate Erin Collins called for the IRS to cease its systemic assessment of international information return penalties and for Congress to amend the Internal Revenue Code to...more
Through the conversion of Law Decree No. 39/2024 into Law No. 67 of 23 May 2024 (the "Tax Bonus Decree"), the Parliament has now approved a number of restrictions substantially limiting the benefits of the so-called...more
On May 17, 2024, the Office of the Attorney-General of the National Treasury (“PGFN”) and the Brazilian Internal Revenue Service (“Brazilian IRS”) jointly published the Public Notice of Settlement for Adhesion No. 6/2024...more
On May 16, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) and the Office of Attorney-General of the National Treasury (“PGFN”) jointly published the Public Notice of Transaction for Adhesion in the Tax...more
On May 13, 2024, the Attorney General's Office of the National Treasury published PGDAU Public Notice No. 2/2024, which creates a new tax settlement method for credits enrolled into federal overdue tax liability, with or...more
On April 24, 2024, the Executive Branch introduced Complementary Bill of Law No. 68/2024 ("PLP 68" or the “Bill”), which creates the Tax and the Contribution on Goods and Services ("IBS" and "CBS") as well as the Selective...more
Le gouvernement du Canada a présenté la tant attendue Loi sur la taxe sur les services numériques (la « Loi ») au Parlement le 30 novembre 2023 dans le cadre du projet de loi C-59. Dans nos Bulletins Blakes antérieurs...more
Canada’s long-anticipated Digital Services Tax Act (Act) was introduced into Parliament on November 30, 2023 as part of Bill C-59. While our previous Blakes Bulletin: 2023 August 4 Draft Legislation: Selected Tax Measures and...more
On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more
The Brazilian Tax Reform on consumption was enacted through Complementary Amendment No. 132/2023, which unified the main taxes on the consumption of goods and services in the form of a Dual VAT and through the creation of a...more
Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more
A recent decision has helped to frame the tests articulated by the Supreme Court in Sequana. The Supreme Court’s landmark decision in Sequana[2022] UKSC 25.leaves many unanswered questions, and finding a common thread...more
La Cour administrative d'appel de Paris rejette la requête de l'administration fiscale tendant à la requalification en salaires de gains réalisés par la holding personnelle d’un dirigeant lors de la cession de titres acquis...more
Below we list some key tax legislative changes that are relevant to new investments in infrastructure projects and that are already in force or have been announced by the government and are under discussion in the National...more
Join Williams Mullen partners for our in-person Winter Tax Forum on Wednesday, January 31, 2024. Our speakers, Farhad Aghdami, Jenny Connors, Conrad Garcia and Beth Hungate-Noland will present on partnership aggregators and...more
On December 19, 2023, the Brazilian IRS published COSIT Answer to Advance Tax Ruling Request No. 308/2023 to clarify the Federal Tax Administration’s position regarding the levy of IRPJ, CSLL, PIS and COFINS on credits...more
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more