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5 Key Takeaways | Artificial Intelligence: What Tax Professionals Need to Know
Avoiding Tax Consequences During Oil & Gas Restructurings
International transactions, such as private equity deals, mergers and acquisitions, and financing arrangements, frequently leverage Luxembourg entities as holding companies or joint ventures. It is common for such companies...more
President Trump’s “One Big Beautiful Bill” (OBBBA) was narrowly passed in the House in May, and while there are many important aspects of the bill, there are provisions that may affect secondary and post-secondary...more
The Democratic Republic of Congo (DRC), home to some of the world’s richest deposits of cobalt, copper, and other critical minerals, enacted major revisions to its Mining Code in March 2018. These reforms marked a significant...more
The Second Panel of the Brazilian Superior Court of Justice (STJ) recently issued a significant decision regarding the time limit for the offset of tax credits recognized in final and unappealable judicial decisions. The...more
The past is prologue: Do REIT qualification issues close with tax years, do they persist for ten (10) years (being the sum of five (5) years on account of the Section 856(g)(3) “lock out” plus another five (5) years of...more
Many closely held businesses operate through entities classified as “S corporations,” an elective federal income tax regime that combines elements of corporate and partnership taxation. Among other reasons, S corporations are...more
On May 22, 2025, the House of Representatives passed H.R. 1-119th Congress (2025-2026), titled as the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses soon to sunset provisions of...more
On May 22, the House of Representatives passed H.R. 1, “The One, Big, Beautiful Bill Act,” legislation authorized under the FY 2025 concurrent budget resolution (H. Con. Res. 14). The bill includes a broad range of...more
The June 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate...more
In just under two weeks, the House of Representatives introduced, modified and passed the One Big, Beautiful Bill of 2025 (the “House Tax Bill”). This Memorandum addresses a new proposed tax on certain persons sending money...more
Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more
The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more
On May 20, 2025, California’s Franchise Tax Board (“FTB”) released changes to the proposed regulations (“Draft Regulations”) that would amend the rules regarding market-based sourcing for sales other than sales of tangible...more
U.S. venture capitalists investing at the early stages (Seed and Series A) in a UK (or other non-U.S.) company often require that the company “flips” its corporate structure and establishes a U.S. (most commonly Delaware)...more
On May 26, 2025, the Mexican Tax Administration Service (SAT) reported a 367% increase in tax revenue from large multinationals audits resulting from enforcing Mexico's transfer pricing rules. From 2019 through 2024, the...more
On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more
There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more
The House’s recent budget bill includes significant tax legislation; however, it does not include any crypto tax provisions. Additionally, the GENIUS Act, which recently moved forward in the Senate and would provide a...more
On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more
Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more
Under the House’s current draft budget bill, which was released on May 15, 2025, the 1.4% excise tax on private universities’ net investment income would increase up to 21%, effectively negating one of the main benefits of...more
On May 15, 2025, the House released the draft FY 2025 budget bill. As currently drafted, the budget bill does not limit or otherwise change the tax treatment of carried interest. Following the release of the budget bill,...more
In the context of medical coverage, the terms “Preventive Services” and “Preventive Care” are often used interchangeably. The two terms, however, have very different meanings. Understanding the difference can have significant...more
On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...more
Earlier this month, New York State Department of Taxation and Finance published a press release explaining what taxpayers should do when they receive a letter from the Tax Department. The press release outlined several...more