On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more
3/5/2025
/ Compliance ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Liquidation ,
Partnerships ,
Penalties ,
Regulatory Agenda ,
REIT ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing...more
1/28/2025
/ Corporate Taxes ,
Employee Retention ,
Estate Tax ,
Foreign Earned Income ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Municipal Bonds ,
SALT ,
Tariffs ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform
On January 20, 2025, the White House issued a memorandum (the “Memorandum”), announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect...more
1/23/2025
/ BEPS ,
Corporate Taxes ,
International Tax Issues ,
IRS ,
OECD ,
Tax Credits ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more
After a more than 26 year hiatus, on July 22, 2022, the Superfund chemical excise tax (the “Superfund Chemical Tax”) will again become effective. This excise tax, reinstated by the passage of the Infrastructure Investment and...more
5/13/2022
/ CERCLA ,
Chemicals ,
Contaminated Properties ,
Environmental Policies ,
Excise Tax ,
Infrastructure Investment and Jobs Act (IIJA) ,
Manufacturers ,
Superfund ,
Tax Liability ,
Tax Planning ,
Tax Reform
On March 28, 2022, the Biden Administration proposed certain very limited changes to the taxation of cryptocurrency transactions. The proposals do not change the current treatment of cryptocurrency as property for federal...more
5/5/2022
/ Biden Administration ,
Bitcoin ,
Cryptocurrency ,
Digital Currency ,
Financial Regulatory Reform ,
Income Taxes ,
IRS ,
Popular ,
Regulatory Agenda ,
Tax Planning ,
Tax Reform
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
1/26/2022
/ Business Taxes ,
Corporate Taxes ,
Domestic Partnership ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
IRS ,
Pass-Through Entities ,
PFIC ,
Proposed Regulation ,
Regulatory Agenda ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform
On October 21, 2021, the Internal Revenue Service (the “IRS”) released Notice 2021-56 (the “Notice”), which sets forth the additional requirements a limited liability company (“LLC”) must satisfy to obtain a determination...more
On Wednesday, April 28th, the White House announced the American Families Plan, the “human capital” infrastructure proposal. The American Families Plan would spend $1.8 trillion, including $800 billion in tax cuts over ten...more
On March 31, 2021, the Biden administration released a factsheet for the “Made in America Tax Plan”. On April 5, 2021, Senate Finance Chair Ron Wyden (D-Ore.) and Senators Sherrod Brown (D-Ohio) and Mark Warner (D-Va.)...more
On March 31, 2021, the White House released a factsheet describing the “American Jobs Plan”, a $2.3 trillion proposal for infrastructure spending that also contains certain significant tax credits, and the “Made in America...more
On January 19, 2021 the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published in the Federal Register Final Regulations (the “Final Regulations”) interpreting the excise tax under Section...more
2/3/2021
/ Compensation & Benefits ,
Deferred Compensation ,
Excise Tax ,
Executive Compensation ,
Final Rules ,
Interim Guidance ,
IRS ,
Remuneration ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Planning
This blog summarizes some of the tax proposals of President-elect Joe Biden and other prominent Democrats.
Biden’s Proposals -
Increased Individual Tax Rate -
Biden would increase the top marginal income tax rate...more
1/14/2021
/ Biden Administration ,
Business Taxes ,
Capital Gains ,
Corporate Taxes ,
Estate Tax ,
GILTI tax ,
Income Taxes ,
Publicly-Traded Companies ,
Tax Credits ,
Tax Planning ,
Tax Rates ,
Tax Reform
On May 12, 2020, House Democrats introduced the Health and Economic Recovery Omnibus Emergency Solutions Act (the “HEROES Act”) (H.R. ___), a $3 trillion stimulus bill that would provide additional relief in response to the...more
On Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax,” with...more
1/29/2020
/ Amended Tax Returns ,
Federal Funding ,
Fringe Benefits ,
Income Taxes ,
IRS ,
New Guidance ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Planning ,
Unrelated Business Income Tax
On December 19, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) under section 1400Z-2 of the Internal Revenue Code...more
1/23/2020
/ Anti-Abuse Rule ,
Capital Gains ,
Community Development ,
Economic Development ,
Final Rules ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Safe Harbors ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more
12/6/2018
/ Anti-Abuse Rule ,
Business Taxes ,
C-Corporation ,
Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
PFIC ,
Proposed Regulation ,
REIT ,
REMIC ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury