News & Analysis as of

Income Taxes

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Lowenstein Sandler LLP

Section 280G Unpacked: Pitfalls and Planning for Tech Startups

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In this episode of Just Compensation, Megan Monson and Jessica I. Kriegsfeld talk to Anthony O. Pergola, Vice Chair of Lowenstein’s Emerging Companies & Venture Capital practice group, about the complexities and challenges of...more

Fenwick & West LLP

House Reconciliation Bill Would Restore Expensing for Domestic R&D Prospectively

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On May 22, 2025, the U.S. House of Representatives passed a reconciliation bill (commonly referred to as the “One Big Beautiful Bill”), which would restore expensing for domestic research and development expenses incurred in...more

Adler Pollock & Sheehan P.C.

Understanding the Ins and Outs of an FLP

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A family limited partnership (FLP) is an estate planning tool with various benefits. These include centralized management of family assets, the ability to transfer wealth without ceding control, reduced gift and estate taxes,...more

White & Case LLP

The IRS Continues Winning Self-Employment Contributions Act (SECA) Tax Against Limited Partners in Private Equity and Hedge Funds

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Recently, the Internal Revenue Service ("IRS") has successfully asserted that limited partners in private equity and hedge funds that are organized as limited partnerships were subject to tax under the Self-Employment...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Investment Funds and Sponsors

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On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more

Amundsen Davis LLC

Does My Company Qualify for Wisconsin’s Voluntary Disclosure Program?

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Taxes and their applicable laws can be confusing for even the most savvy businesspeople. For any number of reasons, businesses and individuals fall out of compliance with tax reporting requirements and become exposed to...more

Akerman LLP - SALT Insights

What’s Next for the Evolution of Public Law 86-272?

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For over 65 years, Public Law 86-272 has dictated a state’s ability to assert income tax on an out-of-state business. While the 1959 federal law predated the emergence of e-commerce and digital services and could not have...more

Whiteford

Client Alert: Inside the One Big Beautiful Bill Crucial Tax Updates for Individuals, Business Owners, and Nonprofits

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On May 22, 2025, the House of Representatives passed H.R. 1-119th Congress (2025-2026), titled as the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses soon to sunset provisions of...more

Warner Norcross + Judd

The Powers and Perils of Intrafamily Loans

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It is not uncommon for family members to lend a helping hand to one another through intrafamily loans. While loans can benefit family borrowers who may not qualify for a traditional loan or who need flexible payment...more

Sheppard Mullin Richter & Hampton LLP

U.S. Budget Bill Targets Foreign Companies with New Tax Hikes: What French Businesses Need to Know

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The One Big Beautiful Bill Act (OBBBA) was passed by the U.S. House of Representatives on May 22, 2025 by a narrow vote of 215-214. OBBBA includes a new U.S. tax provision that could significantly increase taxes on foreign...more

Miles & Stockbridge P.C.

For Whom the Tax Tolls: Maryland’s Budget Bill and Its Fiscal Effects

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Maryland Gov. Wes Moore recently signed the $67 billion state budget for 2026 (HB 352) that will make significant changes to the state’s tax system. Among other changes, the budget bill notably establishes a new tax on IT...more

WilmerHale

Court Decision on Limited Partner Exception to Self-Employment Tax

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On May 28th, the U.S. Tax Court issued a decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) holding that all of the income allocable to the partnership’s limited partners (not just the amount...more

Seward & Kissel LLP

Proposed Tax on Certain Outbound Remittances

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In just under two weeks, the House of Representatives introduced, modified and passed the One Big, Beautiful Bill of 2025 (the “House Tax Bill”). This Memorandum addresses a new proposed tax on certain persons sending money...more

Proskauer - Tax Talks

Senator Tillis Introduced a Bill Taxing Proceeds of Litigation Financing Agreements

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Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more

Proskauer - Employee Benefits & Executive...

The One Big Beautiful Bill Act (Tax Reform): Employee Benefits and Executive Compensation Breakdown

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On May 22, 2025, the House of Representatives passed legislation titled “The One Big Beautiful Bill Act” (the “House Bill”) (available here), which includes several tax reform provisions. The House Bill is now being...more

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

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Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more

Proskauer - Tax Talks

California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules

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On May 20, 2025, California’s Franchise Tax Board (“FTB”) released changes to the proposed regulations (“Draft Regulations”) that would amend the rules regarding market-based sourcing for sales other than sales of tangible...more

Alston & Bird

Asset Managers with California Investors Could Face New State and Local Taxes

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Our State & Local Tax Team breaks down proposals from both California and San Francisco that would use investors’ location to decide whether to tax out-of-state asset managers....more

White & Case LLP

Mexican Tax Authority (SAT) Substantially Increases Transfer Pricing Tax Collections

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On May 26, 2025, the Mexican Tax Administration Service (SAT) reported a 367% increase in tax revenue from large multinationals audits resulting from enforcing Mexico's transfer pricing rules. From 2019 through 2024, the...more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

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Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Cadwalader, Wickersham & Taft LLP

YA Global Brings its Fight to the Appellate Level

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On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more

Pillsbury Winthrop Shaw Pittman LLP

California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

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The proposal includes a shift to a single-sales-factor apportionment formula for financial institutions, aiming to increase tax revenue starting in tax year 2025. Update: On May 14, 2025, Governor Newsom released the May...more

Mayer Brown

Tax Law Highlights | Taxation of Carbon Credits After the Consumption Tax Reform

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AT A GLANCE - Law 15,042/24 (the “Consumption Tax Reform”) was a milestone for the regulation of Brazil's carbon market. It established the regulated market called the Brazilian Emissions Trading System (SBCE), recognized...more

Skadden, Arps, Slate, Meagher & Flom LLP

The One Big Beautiful Bill Act: An Initial Analysis of Key Tax Proposals

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On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more

Fox Rothschild LLP

House and Senate Overtime and Tip Tax Proposals: What Employers Need to Know

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Competing House and Senate bills have the potential to reshape how the IRS taxes tips and overtime wages. The Senate recently passed the “No Tax on Tips Act” while the House budget reconciliation bill proposes deductions for...more

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