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Tax Liability Tax Reform

Bradley Arant Boult Cummings LLP

How Will the Cannabis World Look When Marijuana Is Rescheduled?

A few weeks ago, someone at a holiday party asked “Whitt, why doesn’t Budding Trends take on the weighty legal issues of the day and instead resort to cheap pop culture references and puns?” I thought about responding with a...more

K&L Gates LLP

The Inside Basis: Tax Insurance in Luxembourg

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In our second episode of The Inside Basis, Randy Clark is joined by Marion Zeller, a tax partner in our Luxembourg office, and David Mussche, an associate director with Howden M&A's tax team, to discuss the state of tax...more

Mayer Brown

Supplementary Bill No. 210/2024 – Conversion on Supplementary Law No. 211/2024 After Presidential Sanction

Mayer Brown on

In the last week of 2024, the Brazilian Senate approved Supplementary Bill No. 210/2024 (PLP 210/2024), which includes one of the measures in the government’s cost-cutting package....more

Stikeman Elliott LLP

Prorogation of Parliament and the Proposed Capital Gains Inclusion Rate Increase

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On January 6, 2025, Prime Minister Justin Trudeau announced his resignation as prime minister and the prorogation of Parliament until March 24, 2025. At the federal level, prorogation is an act by the Governor General,...more

Baker Donelson

No More Lists – IRS Concedes on Reportable Transaction Penalties

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Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more

Troutman Pepper Locke

IRS Finalizes New Rules for DeFi Brokers: Challenge Immediately Filed in Texas Federal Court

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The U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations that significantly impact the reporting requirements for brokers involved in digital asset transactions. The stated aim of...more

Polsinelli

Will the Red Wave Crash Down on the Estate Tax Sunset?

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Prior to November 5th, most pundits on both sides of the aisle did not forecast Republicans gaining control of both the Senate and House of Representatives. With Donald Trump being elected to a second term, we now have a “red...more

Stinson LLP

1099-K Reporting: More Time to Transition to the $600 Reporting Threshold

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In the American Rescue Plan Act of 2021, Congress and the Biden administration lowered the minimum reporting threshold for filing information returns relating to “reportable payment transactions” (a payment card is accepted...more

Bennett Jones LLP

CRA Relief and Proposed Amendments Mitigate Bare Trust Reporting Burden on Energy Companies

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On October 29, 2024, the Canada Revenue Agency (CRA) issued a release stating that it will not require bare trusts to file trust returns for the 2024 tax year, continuing the administrative exemption that was granted for the...more

Dechert LLP

Proposed Tax Amendments to Enhance Ireland’s Private Funds Offering

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On October 10, 2024, the Irish government published the Finance Bill 2024 (the “Bill”), which proposes to introduce two important amendments to Irish tax legislation that, when enacted, will positively impact Ireland’s...more

Falcon Rappaport & Berkman LLP

No Tax on Tips: Pragmatic Tax Proposal or Populist Tax Policy Nightmare?

Recently, both major-party presidential candidates have come out in favor of a “no tax on tips” proposals, though neither candidate has indicated how to implement one. There have been proposals from other legislators, though...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

Burr & Forman

Important Update: Florida Sales Tax Reduction on Commercial Leases

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As of June 1, 2024, the State of Florida reduced the state sales tax rate on commercial real property lease payments from 4.5% to 2%. All commercial leases with an occupancy period that started on or after June 1, 2024 will...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

Mayer Brown

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

Mayer Brown on

In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more

Troutman Pepper Locke

The Enemy of the Good: Comparing Administrative v. Legislative Approaches to Cannabis Reform

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Only one day after reports surfaced that the Drug Enforcement Administration (DEA) will proceed with rescheduling cannabis from Schedule I to Schedule III of the Controlled Substances Act (CSA), Senators Charles Schumer...more

Mayer Brown

Public Notice No. 6/2024: Tax Settlement for Credits Arising from Charter and Services Agreements

Mayer Brown on

On May 17, 2024, the Office of the Attorney-General of the National Treasury (“PGFN”) and the Brazilian Internal Revenue Service (“Brazilian IRS”) jointly published the Public Notice of Settlement for Adhesion No. 6/2024...more

Mayer Brown

PGDAU Public Notice No. 2/2024: New tax settlement program for credits up to 45 million reais enrolled into federal overdue tax...

Mayer Brown on

On May 13, 2024, the Attorney General's Office of the National Treasury published PGDAU Public Notice No. 2/2024, which creates a new tax settlement method for credits enrolled into federal overdue tax liability, with or...more

Mayer Brown

Brazilian Tax Reform: Complementary Bill of Law No. 68/2024

Mayer Brown on

On April 24, 2024, the Executive Branch introduced Complementary Bill of Law No. 68/2024 ("PLP 68" or the “Bill”), which creates the Tax and the Contribution on Goods and Services ("IBS" and "CBS") as well as the Selective...more

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Cadwalader, Wickersham & Taft LLP

Proposed Regulations for Buyback Tax Hit LBOs, Preferred Stock but Spare Tier 1 Capital

The government released proposed regulations this month implementing the excise tax imposed on repurchases of corporate stock that was enacted in 2022.  Although these regulations provide some welcome clarity as to the scope...more

Cadwalader, Wickersham & Taft LLP

IRS Hints at Revolution in Tax-Free Spin-Off Rules, Ruling Practice

Over the last three months, public statements by U.S. Treasury and Internal Revenue Service officials have suggested that they are in the process of significantly revising the rules governing tax-free spin-offs, split-offs...more

Mayer Brown

Tax Law Highlights | Brazilian Tax Reform And Expectations For Its Regulation

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The Brazilian Tax Reform on consumption was enacted through Complementary Amendment No. 132/2023, which unified the main taxes on the consumption of goods and services in the form of a Dual VAT and through the creation of a...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

Mayer Brown

Brazil’s New Tax Rules for Infrastructure Investments

Mayer Brown on

Below we list some key tax legislative changes that are relevant to new investments in infrastructure projects and that are already in force or have been announced by the government and are under discussion in the National...more

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