On May 28, 2021, the Biden Administration released the Fiscal Year 2022 Budget, and the “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more
6/16/2021
/ Biden Administration ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
International Tax Issues ,
Like Kind Exchanges ,
NIIT ,
REIT ,
Section 1031 Exchange ,
Self-Employment Tax ,
Tax Credits ,
Tax Reform ,
U.S. Treasury
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
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
Proposed Regulations under Section 4960 of the Internal Revenue Code provide important guidance for tax-exempt organizations and their affiliates regarding an excise tax on certain executive compensation. The U.S. Department...more
7/29/2020
/ Compensation & Benefits ,
Covered Employees ,
Excise Tax ,
Executive Compensation ,
Grandfathering Rules ,
Independent Contractors ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Remuneration ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Reform
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
6/30/2020
/ Capital Gains ,
Corporate Taxes ,
Foreign Tax Credits ,
IRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
REIT ,
Section 199A ,
Tax Cuts and Jobs Act ,
Tax Reform ,
U.S. Treasury
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
On December 20, 2019, President Trump signed into law changes to the private foundation excise tax on net investment income under Section 4940 of the Internal Revenue Code.
For purposes of Section 4940, net investment...more
Late 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.”...more
12/24/2019
/ Employee Benefits ,
Fringe Benefits ,
Income Taxes ,
IRS ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Liability ,
Tax Reform ,
Transportation Expenses ,
Trump Administration ,
Unrelated Business Income Tax
On April 11, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts (including contracts for...more
4/26/2019
/ Fair Market Value ,
Financial Statements ,
Income Taxes ,
IRS ,
Like Kind Exchanges ,
Revenue Procedures ,
Section 1031 Exchange ,
Spectator Sports ,
Sports ,
Tax Cuts and Jobs Act ,
Tax Reform
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform
As we have previously discussed, the 2017 tax reform act created a new excise tax under section 4960 of the Internal Revenue Code that will affect many tax-exempt employers. The tax is 21% of certain compensation and can be...more
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more
1/28/2019
/ Anti-Abuse Rule ,
BEPS ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Income Taxes ,
IRS ,
Parent Corporation ,
Proposed Regulation ,
Subpart F ,
Tax Reform
This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in...more
2/12/2018
/ Acquisitions ,
Base Erosion Tax ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Subsidiaries ,
GAAP ,
GILTI tax ,
International Tax Issues ,
Mergers ,
Net Operating Losses ,
Pass-Through Entities ,
Section 956 ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Reform
Amanda Nussbaum, a partner in the Tax Department and a member of the Not-for-Profit Group at Proskauer, chairs a comprehensive seminar each fall for non-profits to discuss current developments and topics of interest related...more
1/18/2018
/ 403(b) Plans ,
501(c)(3) ,
501(c)(4) ,
Department of Labor (DOL) ,
Employee Benefits ,
Excise Tax ,
Executive Compensation ,
Investors ,
IRS ,
New Rules ,
Partnerships ,
Tax Audits ,
Tax Exemptions ,
Tax Reform ,
Tax-Exempt Bonds
Editor's Overview -
For over two decades, federal law has required covered health plans and insurers to ensure that certain mental health benefits are in parity with offered medical/surgical benefits. The meaning of...more
1/9/2018
/ 401k ,
Affordable Care Act ,
Attorney's Fees ,
Benefit Plan Sponsors ,
Claim Procedures ,
Compensation & Benefits ,
Cost-Sharing ,
Deferred Compensation ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Disability ,
Disability Benefits ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Enforcement Actions ,
Fiduciary Duty ,
Health Savings Accounts ,
Healthcare Facilities ,
Healthcare Reform ,
Income Taxes ,
Individual Retirement Account (IRA) ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
Public Health Service Act ,
QMAC ,
QNEC ,
Securities and Exchange Commission (SEC) ,
Sexual Harassment ,
Shared Responsibility Rule ,
Statute of Repose ,
Tax Deductions ,
Tax Reform ,
User Fees
On Friday, December 22, 2017, President Trump signed into law H.R. 1, the $1.5 trillion tax reform law known as the Tax Cuts and Jobs Act (the “Tax Reform Act”). This alert describes provisions of the Tax Reform Act that we...more
1/4/2018
/ Colleges ,
Educational Institutions ,
Excise Tax ,
Highly Compensated Employees ,
Net Operating Losses ,
Sports ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Reform ,
Tax-Exempt Bonds ,
UBTI ,
Universities
On Friday, December 15, 2017, the Congressional conference committee released a revised version of the Tax Cuts and Jobs Act (the "Tax Bill"). The Senate and the House are expected to vote on the Tax Bill this week. The Tax...more
12/21/2017
/ Alternative Minimum Tax ,
Carried Interest Tax Rates ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Educational Institutions ,
Excise Tax ,
Section 501 ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
UBTI
Over the last several days, there have been significant developments relating to the Tax Cuts and Jobs Act, the pending tax reform legislation in Congress. On Thursday, a detailed summary of the Senate Finance Committee’s...more
11/15/2017
/ 501(c)(3) ,
Colleges ,
Educational Institutions ,
Excise Tax ,
Highly Compensated Employees ,
IP License ,
IRS ,
Logos ,
Pending Legislation ,
Sports ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Reform ,
Tax-Exempt Bonds ,
UBTI ,
Universities ,
Ways and Means Committee
Over the last several days, there have been significant developments relating to the Tax Cuts and Jobs Act, the pending tax reform legislation in Congress. On Thursday, a detailed summary of the Senate Finance Committee’s...more
11/14/2017
/ Charitable Deductions ,
Colleges ,
Educational Institutions ,
Excise Tax ,
Football ,
Highly Compensated Employees ,
IP License ,
IRS ,
Logos ,
Sports ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Reform ,
Tax-Exempt Bonds ,
UBTI ,
Universities ,
Ways and Means Committee
On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership),...more
7/19/2015
/ Capital Gains ,
Carried Interest ,
Cost-Shifting ,
Foreign Investment ,
HMRC ,
Investment Management ,
Pay-for-Performance ,
Resident Non-Domiciled (RND) ,
Tax Deductions ,
Tax Reform ,
UK