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Let It Be…Taxed? The Carried Interest Debate Continues

On February 6, Congressional Republican leaders met with President Donald Trump to address the Trump Administration’s 2025 budget and tax priorities. During that meeting, the Trump Administration proposed to eliminate capital...more

Supporting Employees Impacted by Wildfires

The ongoing Los Angeles, California, wildfires have caused widespread devastation, forcing residents to evacuate, and have destroyed homes and communities. President Joe Biden approved a Major Disaster Declaration in response...more

Five, Six, Seven, Eight, Nine, Ten . . . Will We Love 2024? Top 10 Tax Issues for the Year

The 2024 election year promises to make taxes front-of-mind for many business and individual taxpayers. Beyond the election, there are other note-worthy developments, along with several highly anticipated tax law cases that...more

Because . . . We Said So: Congressional Taxwriters Propose Tax Deal Including Significant Modifications to Employee Retention...

Yesterday, the chairmen of the Senate Finance Committee and the House Ways and Means Committee introduced The Tax Relief for American Families and Workers Act of 2024 (the Act), which proposes changes to the child tax credit,...more

We Can Work It Out: IRS Unveils ERC Voluntary Disclosure Program

As we discussed in our September 25 alert, Everybody’s Got Something to Hide Except Me and My Monkey: IRS Issues Moratorium on Processing New Employee Retention Credit Claims, the Internal Revenue Service (IRS) previously...more

Can You Take Me Back? IRS Unveils Employee Retention Credit Withdrawal Program

As we discussed in our September 25 publishing, Everybody’s Got Something to Hide Except Me and My Monkey: IRS Issues Moratorium on Processing New Employee Retention Credit Claims, the IRS previously stated that it was...more

Fixing a Hole: IRS to Use AI and IRA Funds to Bolster Tax Enforcement

The Inflation Reduction Act (IRA), enacted in August 2022, appropriated billions of dollars in additional funding to the Internal Revenue Service (IRS). The IRS has begun allocating funds, including investing in artificial...more

Everybody’s Got Something to Hide Except Me and My Monkey: IRS Issues Moratorium on Processing New Employee Retention Credit...

The IRS has announced an immediate moratorium on the processing of new employee retention credit claims and warns taxpayers of aggressive promoters and marketers “hustling to get a hefty contingency fee.” On September 14,...more

There’s One for You, Nineteen for Me: IRS Issues Guidance on 1900% Pharmaceutical Excise Tax

The Internal Revenue Service (IRS) has issued guidance on the pharmaceutical excise tax that may apply to certain drug manufacturers, producers, and importers that fail to negotiate a drug-pricing agreement with the US...more

Money (That’s What I Want): IRA’s Direct Pay Mechanism Benefits Tax-Exempt Entities

The Inflation Reduction Act (IRA), which recently celebrated its one-year anniversary, presents new opportunities for tax-exempt and other organizations to directly benefit from renewable energy tax credits, including...more

Come Together, Right Now? US Senate Passes Resolution to Ratify Chile-US Income Tax Treaty

On June 22, 2023, the US Senate passed a resolution consenting to the ratification of the Income Tax Treaty between Chile and the United States (Treaty). The resolution opens the door for President Biden to formally ratify...more

The US Supreme Court to Rule on the TCJA Transition Tax: Is the Realization Requirement Soon to Be No Moore?

On June 26, the US Supreme Court agreed to hear the appeal of Moore v. United States, a development that reverberated throughout the world of tax. The Moore case deals with the constitutionality of the transition tax under...more

The Inflation Reduction Act, Could It be Hello, Goodbye?

On June 9, 2023, US House Ways and Means Committee Chairman Jason Smith introduced the American Families and Jobs Act, which would have major implications for several provisions of the Tax Cuts and Jobs Act of 2017 (TCJA) and...more

The Long and Winding Road: The End of LIBOR

USD LIBOR is the last step in the long and winding road that has been LIBOR’s slow demise over the last several years as all other LIBOR instruments worldwide have already substantially transitioned. As taxpayers prepare...more

“Help Me Get My Feet Back on the Ground”: IRS and Treasury Issue Initial Guidance on Prevailing Wage and Apprenticeship...

On November 29, 2022, the Internal Revenue Service (IRS) and the Treasury issued a Notice of Initial Guidance (the Notice), which provides the first round of guidance with respect to the prevailing wage requirements and...more

You Never Give Me Your Money: Voters Approve Tax Hikes in Massachusetts and Colorado on Election Day

On November 8, 2022, voters in several states considered whether to approve state income tax changes. Specifically, voters in Massachusetts voted to impose a 4 percent personal income surtax on income above $1 million; voters...more

The Inflation Reduction Act's EV Tax Credits: Supply Chain Challenges and Bridge Solutions Under US Trade Rules

Passed in August of this year, the Inflation Reduction Act (IRA) was heralded by many as a landmark piece of climate legislation in the United States. The IRA’s tax credits for electric vehicles were among its most...more

Here Comes the Sun: Treasury and IRS Request Input on Solar and Other Energy Incentives Under the Inflation Reduction Act

Following the enactment of the Inflation Reduction Act (IRA) on August 16, the US Treasury Department (Treasury) and the Internal Revenue Service (IRS) recently issued six notices (the “Notices”) requesting comments on...more

New IRS Technical Guide Creates a Resource for 501(c)(6) Trade Associations

The Internal Revenue Service (IRS) recently published a new Technical Guide for tax-exempt 501(c)(6) trade associations, business leagues, chambers of commerce, real estate boards, and other organizations exempt from federal...more

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more

Senate Finance Committee Provides International Taxation Framework After President Biden Unveils the American Jobs Plan

The proposals in the Framework echo many of the themes set forth in the Made in America Tax Plan. Last week, President Biden outlined an infrastructure spending plan (the American Jobs Plan) and a tax reform plan (the...more

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