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Cadwalader, Wickersham & Taft LLP

Liberty Global Appeals Economic Substance Doctrine Ruling

In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...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

Cadwalader, Wickersham & Taft LLP

The Supreme Court Has Saved the Tax Code for Now and Left Room for Moore

In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT), saving a significant portion of the current tax code for now. The question in front of the Court was whether...more

Bowditch & Dewey

Spousal Relief From Joint Tax Liability

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As a general rule, when a married couple files a joint tax return, they are jointly and severally liable for the entire tax. But what happens if one spouse failed to report income and the other spouse did not know or have...more

Freeman Law

Tax Residency Status Modification: Mexican Tax Implication

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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?

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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

Freeman Law

Texas Tax Roundup | May 2022

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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

Proskauer Rose LLP

UK Tax Round Up - May 2022

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Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Rivkin Radler LLP

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

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Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

McDermott Will & Emery

The Benefits of Investing in a QOF

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Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Foodman CPAs & Advisors

How does the IRS enforce the Nation’s Tax Laws for the benefit of all Taxpayers?

On December 17, 2020, the IRS published a document entitled “Closer Look”. It explains the IRS aspiration for balancing the Taxpayer burden with the potential benefit of its compliance effort when deciding which compliance...more

Fisher Phillips

New Stimulus Package Creates New Tax Reporting Requirements for Gig Economy Businesses

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Gig economy businesses might be unaware of a new requirement in the latest American Rescue Plan stimulus package that is designed to help workers keep track of and correctly pay their taxes each year. The new requirement is...more

Cadwalader, Wickersham & Taft LLP

IRS Proposes Carried Interest Regulations

On July 31, 2020, the IRS and Treasury issued proposed regulations under section 1061 of the tax code. Section 1061 imposes a three-year holding period as a precondition to recognizing long-term capital gains on carried...more

Foodman CPAs & Advisors

IRS issues FATCA Relief but not for All

On September 6, 2019, IRS announced Relief Procedures for Certain Former Citizens.  These are procedures for certain persons who have relinquished, or intend to relinquish, their United States  citizenship, who wish to come...more

McDermott Will & Emery

Still Tax, Even Without the Distributed Cash

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The IRS recently issued guidance on the tax treatment, withholding and reporting for required distributions from tax-qualified retirement plans. Plan sponsors should contact their retirement vendors and trustees to ensure...more

McDermott Will & Emery

Weekly IRS Roundup September 2 – 6, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 2 – 6, 2019. September 3, 2019: The IRS issued a notice in which it released the...more

Bricker Graydon LLP

New guidance on the Tax Cuts and Job Act’s unrelated business taxable income changes

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Recently, the Internal Revenue Service (IRS) released Notice 2018-67 to provide interim guidance to exempt organizations in calculating unrelated business taxable income (UBI)....more

Pierce Atwood LLP

Maine Legislature Passes Tax Conformity Legislation - Now Awaits Governor’s Signature

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In a special session, the Maine legislature passed tax conformity legislation on August 30, 2018, after having failed to pass this legislation prior to its spring adjournment. The legislation is now on the Governor’s desk...more

Bass, Berry & Sims PLC

Sleeper Issue? Deferred Tax Assets under a Trump Administration

Bass, Berry & Sims PLC on

Update as of December 6, 2017: Congress and the President are nearing the finish line for significant tax reform with the likelihood of passing by the end of the year. Since it has the potential to significantly change the...more

Littler

Australia: Tax Changes on the Horizon for Expatriates Working in Australia

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In May 2015, the Abbott Government announced that, as part of its objectives for the Australian federal budget, it will reform the tax residency rules by creating tougher rules and higher income tax bills for the approximate...more

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