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 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
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
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
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
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
In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...more
Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25, 2024 – March 29, 2024....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 13, 2023 – November 17, 2023. ...more
On December 28, 2022, the Treasury Department released a set of proposed regulations that, if finalized, would alter key rules affecting many real estate funds, sovereign wealth funds and other foreign investors in U.S. real...more
On June 9, 2022, the Internal Revenue Service issued Announcement 2022-13, increasing the optional standard mileage rate for the final six months of 2022 from 58.5 cents per mile to 62.5 cents per mile. The new rate will be...more
On January 27, 2022, Governor Jay Inslee signed two bills that delay implementation of the Washington Cares Act to July 1, 2023, including the 0.58% payroll tax, and provide additional exemptions from the program. The Act...more
In a former life, I studied how competent professionals made what turned out to be wrong and sometimes deadly decisions. Often under the general category of “loss of situational awareness,” we had sanitized terms like “target...more
As we enter the final quarter of 2021, there are many things still to do and plan for before the end of the year. There are also some timing considerations given proposed legislative changes and the lead time needed to...more
Seyfarth Synopsis: On December 19, 2019, the U.S. Treasury issued final Qualified Opportunity Zone regulations (the “Final QOZ Regulations”). Subject to the commentary in the Preamble to the Final QOZ Regulations on circular...more
The federal estate tax exemption is now $11.4 million per person ($22.8 million/couple), and the New York State estate tax exemption is now $5,740,000 per person. Generally, the exemption amount is the value of assets that...more
In another round of warnings from the federal government on protecting yourself from tax return fraud and identity theft, the Internal Revenue Service (IRS) has issued its 2019 “Dirty Dozen” Campaign, designed to warn...more
Last week was National Consumer Protection Week. In celebration of that, this post is devoted to protection from tax identity theft. ...more
On February 9, 2018, the Bipartisan Budget Act (the “Act”) was signed into law. The Act directed the IRS to revise regulations governing hardship withdrawal provisions in qualified plans. ...more