Income Taxes

Establishing a Business Entity in Liechtenstein (Updated)

International Lawyers Network on 4/23/2025

The Principality of Liechtenstein lies at the centre of Europe, nestled between Switzerland and Austria, next to the river Rhine. The form of government is a constitutional monarchy established on democratic parliamentary...more

Finally Received the Employee Retention Credit? Now What? A Guide to ERC Income Tax Consequences

Ballard Spahr LLP on 4/23/2025

It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more

Section 83(b) Elections — Should You Pay Taxes Now?

Patterson Belknap Webb & Tyler LLP on 4/23/2025

In startups and early-stage companies, founders often receive restricted equity grants as compensation for their services. With some planning, founders can potentially lower the taxes they pay on the appreciation of the...more

Hobby Loss Rules Revisited

Foster Garvey PC on 4/23/2025

With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more

Made a Mistake on Your Tax Return? What to Do if You Filed Incorrectly

Bowditch & Dewey on 4/23/2025

Mistakes happen, and the tax law can be complex and ambiguous. The question becomes, what does a taxpayer do if they discover a mistake on their tax return? Should an amended tax return be filed? In some cases, the taxpayer...more

Establishing a Business Entity in Malta (Updated)

International Lawyers Network on 4/22/2025

Introduction - With its corporate laws based upon those of the UK, Malta has incorporated laws and principles into its own legislation, providing comfort and security to the commercial and business community. The most...more

President Names Yet Another Acting IRS Commissioner

Fox Rothschild LLP on 4/22/2025

Turmoil continues to roil the highest ranks of the Internal Revenue Service, as the President has replaced the acting IRS Commissioner that he appointed just last week. As we previously wrote, on Tax Day, the President named...more

2025 Perspectives in Private Equity: Tax Analysis

Akin Gump Strauss Hauer & Feld LLP on 4/18/2025

Major portions of the U.S. tax code are scheduled to expire at the end of 2025, and as the U.S. tax landscape faces potential upheaval, private equity firms must stay vigilant and adaptable. Proactively engaging with tax...more

Federal Circuit Holds Generic’s Hatch-Waxman Litigation Expenses Deductible

Axinn, Veltrop & Harkrider LLP on 4/17/2025

A March 21 Federal Circuit decision in Actavis Laboratories FL, Inc. v. United States, No. 23-1320 (Fed. Cir. Mar. 21, 2025) marked a victory for generic drug developers, affirming that legal expenses incurred defending...more

Budget Reconciliation: Using the Current Law vs. Current Policy Baseline

McGuireWoods Consulting on 4/17/2025

As both chambers of Congress worked to pass their versions of the budget resolution, tax writers on the House Ways and Means Committee and Senate Finance Committee, along with their respective leadership, had to decide...more

Canada's Federal Election 2025 — A Tale of Two Tax Policies

Mintz - Tax Viewpoints on 4/17/2025

With the Canadian federal election just under two weeks away, the two major parties leading the current polls, the Liberals (led by Mark Carney) and the Conservatives (led by Pierre Poilievre), have yet to formally release...more

Client Alert: New Maryland Sales Tax on IT Services, Capital Gains and More

Whiteford on 4/16/2025

Just before the close of the 446th legislative session, the Maryland General Assembly passed and sent to Governor Moore HB 352/SB 321, the Budget Reconciliation and Financing Act of 2025 (the “BRFA”). The BRFA, which Gov....more

On Tax Day, President Names New IRS Chief

Fox Rothschild LLP on 4/16/2025

Tuesday, while millions of Americans were busy finalizing their tax returns, the President named a former IRS criminal investigator as the tax agency’s new leader. Gary Shapley, a former IRS special agent who gained...more

Section 1202: Qualified Small Business Stock

WilmerHale on 4/16/2025

This article provides general information regarding U.S. federal income tax incentives available to non-corporate holders of “qualified small business stock” (“QSB stock”) as defined under Section 1202 of the Internal Revenue...more

Mobile Workforce/Remote Worker Legislation Could Impact Your Business

Bradley Arant Boult Cummings LLP on 4/16/2025

Well-respected House Ways & Means-Education Committee Chair Danny Garrett (R-Trussville) has introduced HB 379, a bill designed to provide guidelines and a safe harbor for employers who have traveling employees or remote...more

Georgia’s 2025 legislative session: Tax legislation overview

Eversheds Sutherland (US) LLP on 4/15/2025

During the 2025 legislative session, the Georgia General Assembly passed several notable tax related bills including further decreasing the income tax rate and extending the time period for taxpayers to protest and appeal the...more

M&A Tax Concepts: What is a “Gross-up Payment,” and Why Does It Matter?

Farrell Fritz, P.C. on 4/14/2025

Buying or selling a business is an exciting experience, and potentially lucrative opportunity for all parties. Most often, during the letter of intent / early negotiations phase, a “deal” is struck based primarily on economic...more

Chile: Servicio de Impuestos Internos publica instrucciones sobre facultad de tasación y su aplicación a reorganizaciones...

DLA Piper on 4/14/2025

El Servicio de Impuestos Internos (SII) dictó la Circular N°23 que imparte instrucciones sobre el nuevo texto del artículo 64 del Código Tributario. A modo de contexto, el SII tiene una facultad legal para tasar el precio o...more