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Tax Code Tax Planning

Allen Barron, Inc.

Surprising IRS Tax Bracket Changes for 2025

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Have you come across the surprising IRS tax bracket changes for 2025? Yesterday, the IRS released the 2025 income tax brackets for U.S. taxpayers. The inflation adjustments to tax brackets were a pandemic-boosted 7% for...more

Cadwalader, Wickersham & Taft LLP

Recognising “Imported Losses” Under the UK’s Loan Relationship Rules

The United Kingdom (“UK”) has specific corporate tax rules on the taxation of loan relationships (parts 5 and 6 of the Corporation Tax Act 2009 (the “Loan Relationships Regime”)). The Loan Relationships Regime contains rules...more

Seward & Kissel LLP

Final Tax Rules and Transitional Guidance for Broker Reporting

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The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more

Davidoff Hutcher & Citron LLP

Global Wealth, Local Laws: What 8 International Estate Planning Issues Should High-Net-Worth Individuals Consider?

Navigating International Estate Planning - Today, more and more people own property in more than one country, and that requires particular consideration when planning their estate. Traveling has become so easy that many...more

Bowditch & Dewey

Olympic Medals and Income Tax

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The 2024 Paris Olympics are in full swing, and it is never too early for U.S. athletes to consult with their tax advisor. As was done in 2021, the United States Olympic & Paralympic Committee has pledged to award U.S....more

Mayer Brown

Measure ULA Update: Reported Revenue, Applicability to Foreclosures and Legal Challenges

Mayer Brown on

In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...more

Hogan Lovells

A new form of security in Italy: Non-possessory pledge of moveable goods

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In 2016, Italy introduced a new form of security on moveable goods, which does not require the debtor to surrender the goods to the creditor or a custodian. Instead, it requires the pledgor to register the goods in a digital...more

Carlton Fields

Tax Court Upholds IRS Decision That Premiums Paid to Microcaptive Insurance Companies Did Not Qualify for Tax Deductions

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The U.S. Tax Court recently upheld a determination by the IRS that premium payments to certain microcaptives could not be deducted for tax purposes because the premium payments were not actually for “insurance.”...more

Allen Barron, Inc.

The Sunset of the TCJA – Tax Cuts and Jobs Act of 2017 – Is Scheduled for the End of 2025

Allen Barron, Inc. on

The sunset of the TCJA – the Tax Cuts and Jobs Act of 2017, is currently scheduled for the end of 2025.  The TCJA contributed substantial changes to the US tax code that have benefited many US taxpayers.  How should a US...more

Morgan Lewis

Biden Highlights IRS Plans to Audit Corporate/Partnership Jet Use in State of the Union Address

Morgan Lewis on

In his State of the Union address, President Joseph Biden targeted tax breaks for corporations and wealthy individuals who use private jets as part of a broader goal to make big corporations and the wealthy pay “their fair...more

King & Spalding

France – New Offense of Providing Instruments to Facilitate Tax Fraud

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The fight against tax fraud occupies a central place in the French Finance Act for 2024. Among the various proposals is the new Article 1744 of the French tax code, which creates the offense of making instruments...more

Poyner Spruill LLP

Exploring Estate Tax Deferral

Poyner Spruill LLP on

The passing of a loved one is always a challenging time and navigating the financial implications of administering his or her estate can add yet another layer of complexity to an already emotional experience. Estate Taxes, in...more

Adler Pollock & Sheehan P.C.

Does Your Estate Plan Account For Generation-Skipping Transfer Tax?

Does your estate plan call for making gifts to your grandchildren or other loved ones more than one generation below you? Or, perhaps to nonrelatives more than 37½ years younger than you?...more

McDermott Will & Emery

Advanced Planning Can Reduce Your Tax Burden When Buying Property or Moving to the United States

Moving to or purchasing real estate in the United States as a nonresident requires careful consideration of US federal income, estate and state and local tax laws. Inbound US federal tax planning involves analyzing these laws...more

Freeman Law

Tax Residency Status Modification: Mexican Tax Implication

Freeman Law on

For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living. And in an increasingly global...more

Freeman Law

Texas Tax Roundup | November 2022: What’s a Franchise Tax?

Freeman Law on

Hey everybody! Welcome back to another for another edition of Texas Tax Roundup! Hope y’all had a happy Thanksgiving! We got some franchise tax apportionment, some sales and use tax in the oil and gas industry, and some...more

Allen Matkins

Attention Property Owners: Los Angeles and Santa Monica Approve ‘Mansion Tax’ Ballot Measures, Increasing Transfer Taxes on Sales...

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Residents of Los Angeles have approved Measure ULA, a ballot measure widely known as the “Mansion Tax,” which increases transfer tax rates on real estate sales valued at $5 million or more. Prior to Measure ULA, real estate...more

Freeman Law

Texas Legislature Adds Suits After Redetermination as Option to Challenge State Tax Assessments

Freeman Law on

In 2021, the Texas Legislature made it easier for taxpayers to challenge tax assessments without first paying the disputed amounts of tax due. Prior to this change, pay-to-play was the only game in town. Under pay-to-play, a...more

Freeman Law

Applying Texas Sales and Use Tax to New Construction and Real Property Repair and Remodeling Services

Freeman Law on

One of the more complicated areas involving Texas sales and use tax is the taxation of various new construction and real property repair and remodeling services. Determining what’s taxed and what’s not requires delving...more

Freeman Law

Texas Tax Roundup | May 2022

Freeman Law on

Howdy folks, and welcome back to another captivating installment of Texas Tax Roundup, where we gab about all things Texas taxes. Nothing court-side this month, just a bunch at the administrative level. Still, it’s...more

Freeman Law

Texas Religious Organizations Property Tax Exemption

Freeman Law on

Through nearly 20 years of law practice–15 of which have been focused on the representation of tax-exempt organizations–this writer has been involved in numerous seemingly simple–and some cutting edge–applications for...more

Littler

Puerto Rico Department of the Treasury Announces 2022 Limits on Qualified Retirement Plans

Littler on

On January 14, 2022, the Puerto Rico Department of the Treasury issued Internal Revenue Circular Letter No. 22-01 (CL IR 22-01) announcing the applicable 2022 limits for Puerto Rico qualified retirement plans. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Build Back Better Act Would Change Monetization Playbook for Tax-Free Spin-Offs

If enacted in its present form, the Build Back Better Act (BBBA) would amend the U.S. tax code’s rules for tax-free spin-off and split-off transactions (spin-offs), imposing significant restrictions on a parent company’s...more

Hogan Lovells

Impuestos a las Plataformas Digitales - Iniciativa Ciudad de México

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La Jefa de Gobierno de la Ciudad de México presentó una iniciativa por virtud de la cual se adiciona el artículo 307 TER al Código Fiscal de la Ciudad de México el cual tiene por objeto que las personas físicas o morales que...more

Bowditch & Dewey

Massachusetts Taxpayers Find More Complexity in Differences Between Massachusetts and Federal Tax Law

Bowditch & Dewey on

It seems every year there are changes to the Internal Revenue Code (IRC). It is a challenge, even for tax pros, to keep up with the ever-changing tax code. Massachusetts taxpayers also have an added challenge in keeping up...more

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