On March 11, 2024, the Biden Administration released the Fiscal Year 2025 Budget, and the “General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals,” which is commonly referred to as the “Green Book.”...more
3/28/2024
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Digital Assets ,
Excise Tax ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
Liquidation ,
NIIT ,
Property Tax ,
Tax Policy ,
Tax Reform
On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more