In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more
As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us.
Review of U.S. Tax Developments in 2022-
In 2022 we...more
With another new year nearly upon us, we call attention to regulatory changes to the Stock Buyback Excise Tax that will be proposed to take effect on January 1 and the implications on more non-U.S. corporations. Specifically,...more
The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments,...more
8/18/2022
/ Biden Administration ,
Carried Interest ,
Climate Change ,
Corporate Taxes ,
Enforcement ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
IRS ,
New Legislation ,
Portfolio Companies ,
Share Buybacks ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Wealth Tax
Review of U.S. Tax Developments in 2021-
Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more
3/4/2022
/ Anti-Injunction Act ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
BEPS ,
Capital Gains ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
Infrastructure ,
IRS ,
Joe Biden ,
Like Kind Exchanges ,
Net Investment Income ,
OECD ,
PFIC ,
Popular ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Tax Treaty ,
U.S. Treasury