On August 7, 2022, the Senate passed a major climate, health and tax bill through the budget reconciliation process. The bill, named the Inflation Reduction Act of 2022, is expected to be taken up by the House of...more
Section 1202 is a once-obscure tax saving provision that has come into prominence in the last few years. Originally passed in 1993 as a 50% capital gain exclusion, it has been amended several times since. In its current...more
On September 13, 2021, the House of Representative Ways and Means Committee introduced tax proposals that, if enacted, would make significant changes to the U.S. federal income tax system. This Alert summarizes some of the...more
On July 16 and 17, 2019, the U.S. Senate approved resolutions of ratification of protocols to amend existing income tax treaties between the United States and various countries, including Spain, Japan, and Switzerland. Before...more
Both the House of Representatives and the Senate have proposed their own versions of tax reform (the “House Proposal” and “Senate Proposal”, respectively, and together, the “Proposals”) which will drastically change the...more
11/27/2017
/ Carried Interest Tax Rates ,
Corporate Taxes ,
FIRPTA ,
Income Taxes ,
Pass-Through Entities ,
Pension Funds ,
SALT ,
Self-Employment Tax ,
State and Local Government ,
State Taxes ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
UBTI
A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more
3/15/2017
/ Appeals ,
Corporate Taxes ,
Dividends ,
Domestic International Sales Corporation ,
Holding Companies ,
Internal Revenue Code (IRC) ,
Reversal ,
Roth IRA ,
Shareholders ,
Substance Over Form Rule ,
Tax Court ,
Transfer Pricing
Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more
5/2/2016
/ Affiliates ,
Anti-Inversion Regulations ,
Comment Period ,
Controlled Groups ,
Corporate Taxes ,
Debt ,
IRS ,
Multinationals ,
Parent Corporation ,
Proposed Regulation ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury