Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
Musings on Multinational Tax: What to Expect From GILTI Conscience
4 Key Takeaways | Mid-Year Tax Update
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
III-39 - 2nd Anniversary Special Episode
Qualified Opportunity Zone Fund Investments
[WEBINAR] Labor & Employment Law: What Changed in 2017
Impact of Tax Reform on Charitable Giving
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Life Sciences Quarterly: Tax Cuts and Jobs Act: Implications for Life Science Business
Private equity investments
II-27 - Our 1st Anniversary Special: Bringing Back Our Inaugural Guest to Discuss What Was and What Will Still Be With President Trump
II-26 – Superbowl Concerns, Tax Reform/MeToo, Restrictive Covenant Crimes, and Expanded Religious Discrimination Theories
II-25 – Top 10 New Year’s Resolutions for Employers in 2018
The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more
Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more
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
On January 25, 2022, the IRS and Treasury proposed regulations that would treat U.S. partners, instead of their partnerships, as PFIC shareholders for making qualified electing fund, mark-to-market, or purging elections,...more
On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more
On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more
On April 23, the Treasury Department and the Internal Revenue Service (the "IRS") issued helpful proposed regulations under section 512(a)(6) of the Internal Revenue Code (the "proposed regulations"). Section 512(a)(6) was...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more