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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

DarrowEverett LLP

What Florida Sales Tax Cut Means for Florida Commercial Tenants

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Broadly speaking, according to the Florida Department of Revenue, each Florida sale, amusement park admission, storage unit and rental is taxable (unless it falls under an exemption, such as nonprofits). More specifically,...more

DarrowEverett LLP

Accidental Termination on Purpose? S Corp Ruling Could Be Huge For QSBS Owners

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Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...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

Mayer Brown

Brazil Tax News: Laws, Provisional Measures, Normative Instructions, and Bill of Law Approved at End of December 2023

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Several new rules were approved on December 28, 2023, all extremely relevant to tax law. Our tax team summarizes some of the more relevant new rules...more

McDermott Will & Emery

The Tax Implications of Purchasing Craft Producers in the First Half of a Year

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If a large beverage company is considering purchasing or selling a craft beverage producer, it’s essential to understand how the craft producer may lose its earlier eligibility for reduced tax rates under the Craft Beverage...more

Cadwalader, Wickersham & Taft LLP

Potential Constitutional Challenge: Biden Budget Proposes Mark-to-Market for High-Net-Worth Individuals

In President Biden’s State of the Union address, he called on all Americans to pay their “fair share.” The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals contains several...more

Burns & Levinson LLP

State Solutions to the “280E Problem”

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Does anyone else feel immense frustration when considering the inequitable treatment that cannabis businesses receive under Section 280E of the Internal Revenue Code (26 U.S.C. s. 280E)? It grinds my gears that our clients,...more

Brownstein Hyatt Farber Schreck

Taxation & Representation. Feb. 15, 2023

TAX TIDBIT - Progress on Werfel and Blatchford Appointments, Other Nominations Delayed. Following the retirement of former IRS Commissioner Chuck Rettig in early November 2022, the tax-administration agency has been...more

Nutter McClennen & Fish LLP

Key Considerations When Planning for the Massachusetts ‘Millionaires Tax’

On November 8, 2022, Massachusetts voters approved an amendment to the Massachusetts Constitution imposing, effective January 1, 2023, a surtax of 4% on an individual’s annual taxable income to the extent it exceeds $1...more

Burr & Forman

Changes in Tax Rates for 2023

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The IRS has issued Revenue Procedure 2022-38, which sets forth inflation-adjusted items for various provisions of the Internal Revenue Code which will be applicable in 2023. Here are some of the highlights...more

A&O Shearman

Volatile Reaction to UK “Mini-Budget”

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Bank of England market intervention after presentation of tax package - On 23 September, the new U.K. Government conducted the emergency fiscal event it had scheduled when taking power at the beginning of the month. Many...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

Brownstein Hyatt Farber Schreck

Taxation and Representation, July 12, 2022

Reconciliation Revival? Ever since Sen. Joe Manchin (D-WV) publicly renounced his support of the House-passed Build Back Better Act (BBBA) in December of last year, the prospects of a reconciliation bill have appeared grim...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 14, 2022

Kustoff Joins Ways and Means. Rep. David Kustoff (R-TN) has been selected to replace former Rep. Tom Reed (R-NY), who resigned from Congress earlier this year, on the House Ways and Means Committee. He will sit on the Worker...more

Burns & Levinson LLP

VAS Holdings v. Commissioner of Revenue - Taxing Out-of-State Entities on the Sale of a Massachusetts Business

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What Was At Stake - At issue in a recent, significant tax decision of the Supreme Judicial Court (“SJC”) was whether the Massachusetts Commissioner of Revenue could tax an out-of-state shareholder on the gains it derived...more

Brownstein Hyatt Farber Schreck

Tax & Financial Services Week Ahead - April 4, 2022

The House and Senate will meet Monday at 2 p.m. and 3 p.m., respectively....more

Freeman Law

Notable Tax Takeaways from President Biden’s Budget

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On March 28, 2022, President Joe Biden released his FY 2023 Budget of the U.S. Government (the “Budget”). In a statement regarding the Budget, President Biden stated the following...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

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On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Proskauer Rose LLP

UK Tax Round Up - November 2021

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Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more

Davies Ward Phillips & Vineberg LLP

Revised U.S. Tax Proposals Will Affect Foreign Investment

The U.S. House Committee on Rules recently released an updated version of the Build Back Better Act (Act) to reflect the White House’s Build Back Better framework (Framework) announced on the same day (October 28, 2021). ...more

Miller Nash LLP

When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)

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The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more

Proskauer - Tax Talks

A step closer to agreement on taxation of the digital world

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On 8 October 2021, the OECD released a further statement in relation to the BEPS 2.0 proposals, aimed at addressing taxation of the modern digital economy. This is the latest development in the attempts to more equally share...more

Foster Garvey PC

Global Tax Reform Takes a Major Step Forward as 136 Nations Sign on to OECD BEPS 2.0 Framework

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On Friday October 8, 2021, the Organization for Economic Cooperation and Development (OECD) announced that 136 Nations, including the United States and the rest of the G20, have signed on to the OECD/G20 Inclusive Framework...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

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...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

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