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IR Global

Planning for the uncertain - The Visionaries

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Q1 How should businesses and individuals prepare for and respond to new governments across the world? Governments play a pivotal role in shaping the financial landscape by imposing regulations, setting corporate and...more

Eversheds Sutherland (US) LLP

Clarifying the federal tax classification of wholly owned tribal entities and the mechanics of the Section 6417 election for such...

On October 7, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) clarifying the federal tax classification of certain entities wholly owned by...more

Cadwalader, Wickersham & Taft LLP

Presidential Candidates’ Tax Proposals Diverge on the Road to November

The outcome of the upcoming elections is likely to significantly impact future tax legislation.  Notably, many tax provisions enacted under prior tax legislation, commonly called the Tax Cuts and Jobs Act (the “TCJA”), will...more

Cadwalader, Wickersham & Taft LLP

Give Unto Caesar – Crypto?

On June 25, 2024, Congressman Matt Gaetz (R-FL) introduced H.R. 8822 (the “Bill”), which would add Section 6316A to the Code, allowing individuals to pay their federal income tax using Bitcoin. According to Gaetz, “enabling...more

Mayer Brown

Could 2025 Bring the Biggest Changes in US Tax Policy in History? Absolutely!

Mayer Brown on

2025 may well be the most consequential year in the history of US tax policy, at least since the establishment of the income tax through the 16th Amendment in 1913. While the US has a long history of enacting tax policies...more

Nelson Mullins Riley & Scarborough LLP

Gold Dome Report - Legislative Day 40 - March 2024

Legislative Day 40 is a roller coaster, full of ups, downs, and zero gravity turns (also known as conference committee reports). One goes from celebrating a bill achieving final passage to lamenting a measure being gutted...more

Nelson Mullins Riley & Scarborough LLP

Gold Dome Report - Legislative Day 37 - March 2024

Senate committee meetings continue under the Gold Dome as this report is published on Wednesday. With the Senate’s requirement that bills pass out of committee before the chamber convenes for Legislative Day 38, legislators...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Nelson Mullins Riley & Scarborough LLP

Gold Dome Report - Legislative Day 29 - March 2024

While legislators and lobbyists continued to nurse the hangover of Crossover Day, the most unlikely of events unfolded in the Georgia State Senate on Monday. Senate Majority Leader Steve Gooch (R-Dahlonega) awarded the...more

Nelson Mullins Riley & Scarborough LLP

Gold Dome Report - Legislative Day 28 - March 2024

Thursday carried several distinctions under the Gold Dome. It was Leap Day, the quadrennial opportunity to celebrate those born on Feb. 29. It was Crossover Day, the day we all have to explain to our significant others each...more

Holland & Knight LLP

Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?

Holland & Knight LLP on

En este episodio de "A Lo Legal En Par Minutos", nuestro abogado Edwin Cortés conversa con Gustavo Pardo, socio del área tributaria, sobre el impacto de la reforma tributaria de 2022 en Colombia. Nuestros abogados abordan...more

Conyers

Bermuda Regulatory Outlook 2024

Conyers on

As we enter 2024 the myriad of regulatory changes can appear overwhelming. We are here to help and have set out below some key changes and issues that can impact Bermuda entities. Bermuda has introduced a corporate income tax...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

McDermott Will & Emery

New From January 2024 | Participation Exemption for European Corporations on Disposal of Shareholdings

McDermott Will & Emery on

The Italian government recently approved a draft 2024 budget law which provides for the extension of the domestic participation exemption regime on disposal of shareholdings (PEX) to those non-resident corporations that: (i)...more

Stikeman Elliott LLP

Tax Base Erosion: Canada Responds with Draft EIFEL Rules Legislation

Stikeman Elliott LLP on

On August 4, 2023, the Department of Finance released an updated version of the draft legislation that will incorporate the excessive interest and financing expense limitation rules (“EIFEL Rules”) into the Income Tax...more

Cadwalader, Wickersham & Taft LLP

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.  By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

White & Case LLP

Czech Taxes Increase as of 2024

White & Case LLP on

The Czech government introduced a consolidated proposal to fight growing budget deficits, consisting of cutting subsidies and otherwise mostly increasing taxes as of 2024. This is a high-level review of those tax measures...more

Pillsbury Winthrop Shaw Pittman LLP

A Hat Tip to the Manufacturing, R&D and Electric Power Industries: California Bill Would Provide Income Tax Credits for Sales and...

California’s Existing Partial Exemption for Statewide Sales and Use Tax Paid on Qualified Tangible Personal PropertyRTC section 6377.1 exempts from certain state sales and use taxes the sale of, and the storage, use or other...more

Mayer Brown

US Treasury to Propose Regulations on Energy Community Bonus Adders

Mayer Brown on

On April 4, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of intent to issue proposed regulations on qualifying for the energy community bonus credit under Sections...more

McDermott Will & Emery

Weekly IRS Roundup March 13 – March 17, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...more

Pullman & Comley - For What It May Be Worth

March 10 Public Hearing on Bills Impacting Connecticut Taxpayers

On March 10, 2023 at 11:00 a.m., the Connecticut General Assembly’s Planning and Development Committee will hold a public hearing on the following bills of interest to both commercial and residential taxpayers...more

McDermott Will & Emery

Weekly IRS Roundup December 12 – December 16, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 12, 2022 – December 16, 2022...more

Freeman Law

IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning

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Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning - On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under...more

Cadwalader, Wickersham & Taft LLP

To Elect or Not to Elect: U.S. Partners May Soon Have to Decide for Themselves Whether to File Passive Foreign Investment Company...

U.S. partners in U.S. partnerships that invest in PFICs may soon be responsible for filing elections previously filed by the partnership. Under current regulations, U.S. partners may rely on entity-level mark-to-market...more

Cadwalader, Wickersham & Taft LLP

Senate Passes Inflation Reduction Act

Below is a summary of the tax provisions in the Inflation Reduction Act of 2022 (the “IRA”), as passed by the Senate, that are likely to be of most interest to U.S. corporate taxpayers, financial institutions, hedge funds,...more

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