Avoiding Tax Consequences During Oil & Gas Restructurings
During the last decade, the shape and source of capital flows and investment have fundamentally shifted. Private capital continues to flow into all asset classes including real estate, infrastructure, private credit, and...more
In a unanimous opinion delivered by Justice O'Brien, the Illinois Supreme Court affirmed that the Illinois Department of Revenue (IDOR) has exclusive jurisdiction over sales tax misallocation disputes between municipalities....more
The Iowa Legislature returned after the first funnel deadline in Week 8 and the pace shifted as the Iowa House and Senate spent more time on floor debate and attention shifted to Ways and Means and Appropriations bills and...more
In November 2024, voters approved Proposition M which provided for an overhaul of San Francisco’s gross receipts tax. Proposition M changed the allocation and apportionment rules for most industries, generally requiring that...more
COMPETITION - Prior notification of a concentration (Case M.11746 - DSV / Schenker) - Prior notification of a concentration (Case M.11911 - ETA / SPL / SP Mobility)...more
Smith v. Commissioner, a pending research credit case in the United States Tax Court, presents an issue of first impression: Is a partner’s self-employment income in a partnership allowable as a qualified research expense...more
COMPETITION - Non-opposition to a notified concentration (Case M.11819 - Audi / Qatar Holding / Sauber Hodling) - Commission carries out unannounced antitrust inspections in the non-alcoholic drinks sector and asks for...more
Kilpatrick’s Jordan Goodman recently joined other thought leaders at the ABA-IPT Advanced State Income, Advanced Sales/Use, and Advanced Property Tax Seminar in New Orleans where he co-presented on the latest twists in sales...more
The Brazilian Supreme Court (STF) decided that the Tax on Services’ (ISS) non-levy on toll commissioned manufacturing activities, whenever these activities refer to the intermediary activities of a production cycle. The...more
You may have heard recently about proposals for Congress to remove the exclusion from gross income of interest on state and local bonds, usually referred to as “repealing the tax exemption on municipal bonds.” This issue...more
On February 18, the New Jersey Division of Taxation published proposed corporation business tax (CBT) regulations that incorporate changes associated with 2023 reform legislation, as well as additional changes intended to...more
COMPETITION - Prior notification of a concentration (Case M.11786 - Mondi / Schumacker Packaging (German & Dutch & UK Business)) Prior notification of a concentration (Case M.11867 - Daikin / Copeland / C-D Compression...more
The Michigan Department of Treasury released a draft of a notice regarding the new research and development credit. ...more
Introduction - After a long gestation, the much heralded new UK fund structure, the Reserved Investor Fund (“RIF”) is finally expected to be available from 19 March 2025....more
Tax developments - The validity of the 245A DRD for indirectly owned foreign corporations - On January 21, 2025, the IRS filed a motion for summary judgment asking the Tax Court to hold that Sysco Corporation (Sysco)...more
Lots of folks have been asking of late, “Do I have to show taxes in drink prices?” No. The law gives taxpayers two options....more
Ohio lawmakers are moving to tighten hemp regulations following Governor Mike DeWine’s call to “regulate intoxicating hemp” and close legal gaps that may allow the marketing and sale of hemp products to minors. Senators Shane...more
New Mexico’s gross receipts tax (what the state calls its sales tax) is generally imposed on receipts derived by the seller from performing services in the state; however, a resale of the services is not generally taxable if...more
It has always been prudent to search for firms who can integrate legal, tax, accounting and business advisory services. While there are few such genuine providers across the United States they do exist, and the KPMG Arizona...more
The Georgia General Assembly returned in a frenzy on Tuesday with lawmakers and lobbyists rushing between back-to-back committee meetings in the morning and afternoon on a legislative day bifurcated by a 1 p.m. convening....more
The California Department of Tax and Fee Administration (CDTFA or Department) hosted its third workshop (Workshop III) on December 9, 2024, to discuss and receive input on technology transfer agreements (TTAs)....more
Late last year, the Office of the State Comptroller (the “OSC”) estimated that sales and use tax receipts would increase by 2.3% in the SFY 2024-2025. The OSC also projected that collections from sales and use taxes would...more
On February 4, 2025, and by unanimous vote, the Brazilian Supreme Court’s (STF) Plenary confirmed that the non-levy of ICMS will only apply from the 2024 fiscal year, with the exception of administrative and judicial...more
President Donald Trump made headlines when he announced an External Revenue Service (ERS) agency to collect tariff incomes. The announcement sparked a heated debate among trade experts, economists, and business leaders. But,...more
The UAE government has taken steps to move towards a fully digitized tax system by adopting E-Invoices. The E-invoicing process will be mandatory for all business to business (B2B) and business to government (B2G)...more