Upcoming Eversheds Sutherland event -
Join us for a two-day controversy seminar in Washington, DC covering legislative reviews, state, federal, and international tax updates, LB&I hot topics, appeals, transfer pricing,...more
Tax developments -
Other countries’ response to United States position on the Global Tax Deal -
On Friday, President Trump issued a memo discussing his administration’s intent to defend US companies from unfair foreign...more
The final judicial barrier to the Financial Crimes Enforcement Network’s enforcement of the Corporate Transparency Act’s beneficial ownership information (BOI) reporting requirements has been lifted.
The Corporate...more
On December 26, 2024, the US Court of Appeals for the Fifth Circuit changed course, effectively reinstating the preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA)....more
12/31/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reinstatement ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Time Extensions ,
Vacated
On December 3, 2024, the US District Court in the Eastern District of Texas (the Texas Federal Court) granted a nationwide preliminary injunction in favor of certain small businesses, ruling (1) the Corporate Transparency Act...more
12/17/2024
/ Beneficial Owner ,
Business Ownership ,
Corporate Transparency Act ,
Disclosure Requirements ,
FinCEN ,
Injunctions ,
Popular ,
Preliminary Injunctions ,
Reporting Requirements ,
Small Business ,
Suspended Judgment ,
Unconstitutional Condition
On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more
7/18/2024
/ Excise Tax ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
Regulatory Agenda ,
REIT ,
Reporting Requirements ,
RICs ,
Share Buybacks ,
Stock Repurchases ,
U.S. Treasury
In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...more
1/31/2024
/ Affordable Housing ,
Congressional Committees ,
Filing Requirements ,
FIRPTA ,
Foreign Corporations ,
Low Income Housing ,
Mortgage REITS ,
Proposed Legislation ,
Relief Measures ,
Taiwan ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders ,
Tax Treaty
On December 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published Notice 2024-16 (Notice) announcing their intent to issue proposed regulations relating to the determination of...more
On June 29, 2023, the Internal Revenue Service (IRS) issued Announcement 2023-18 (the Announcement), which provides transitional guidance with respect to the stock repurchase excise tax under section 4501 (the Buyback Tax)....more
Nearly two months ago, on August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the provisions of the IRA is a nondeductible 1% excise tax on the repurchase of corporate stock (the Buyback...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more
8/18/2022
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Biden Administration ,
Corporate Taxes ,
Financial Statements ,
GAAP ,
IFRS ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
REIT ,
Tax Cuts and Jobs Act ,
Tax Rates
The US Treasury is moving to formally withdraw from the US-Hungary income tax treaty, which has been in effect since 1979 (the Treaty). For previous reporting by Eversheds Sutherland regarding the Treaty, see US-Hungary tax...more