On his first day in office, among the numerous Executive Orders (EO) released, President Donald Trump announced the America First Trade Policy EO designed to prioritize American interests in international trade and tax and,...more
1/31/2025
/ America First Trade Policy ,
Corporate Taxes ,
Executive Orders ,
International Tax Issues ,
International Trade ,
OECD ,
Section 301 ,
Tariffs ,
Tax Reform ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies
Private Wealth Services attorneys Patrick Duffey and Brent Berselli discuss the future of tax policy with Tax attorney Joshua Odintz ahead of the 2024 election. The attorneys provide an overview of the 2017 Tax Cuts and Jobs...more
In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more
6/13/2024
/ Administrative Procedure Act ,
Conservation Easements ,
Corporate Taxes ,
Easements ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Tax Appeals ,
Tax Avoidance ,
Tax Court ,
Tax Penalties ,
Tax Shelters
The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more
6/3/2024
/ Audits ,
Bipartisan Budget Act ,
Corporate Taxes ,
Default ,
IRS ,
Jurisdiction ,
Partnerships ,
Tax Court ,
Tax Liability ,
Tax Returns ,
TEFRA
The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, Docket No. 10819-21, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the...more
5/31/2024
/ Anti-Abuse Rule ,
C-Corporation ,
Complex Corporate Transactions ,
Corporate Taxes ,
IRS ,
Real Estate Development ,
Real Estate Transfers ,
Recharacterization ,
Related Parties ,
Tax Court ,
Tax Deferral ,
Tax Planning ,
Tax-Deferred Exchanges
The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more
2/2/2023
/ Acquisitions ,
Affiliates ,
Comment Period ,
Corporate Taxes ,
Covered Entities ,
Domestic Corporations ,
Excise Tax ,
Fair Market Value ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Liquidation ,
Reorganizations ,
Stock Redemption ,
Stock Repurchases ,
U.S. Treasury
As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA)....more
Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the Base Erosion Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD)/G-20...more
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more
6/11/2021
/ Biden Administration ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax ,
Foreign Tax Credits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
Multinationals ,
OECD ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
U.S. Treasury
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more
6/4/2021
/ Appropriations Bill ,
Biden Administration ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Internal Revenue Code (IRC) ,
IRS ,
OECD ,
Proposed Legislation ,
Tax Reform ,
U.S. Treasury
Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap in the U.S. may total $1 trillion per year. In his view, the increase from prior estimates is due, in part,...more
5/7/2021
/ Biden Administration ,
Congressional Committees ,
Congressional Investigations & Hearings ,
Corporate Taxes ,
Cryptocurrency ,
Income Taxes ,
IRS ,
Large Business & International Division (LB&I) ,
Offshore Funds ,
Proposed Legislation ,
Tax Audits ,
Tax Evasion ,
Tax Haven ,
Tax Loopholes ,
Tax Reform ,
Wealth Tax
The American Jobs Plan is a proposal to increase investment in infrastructure, the production of clean energy, the care economy and other priorities. The Made in America Tax Plan (Tax Plan) is the vehicle to pay for the...more
4/16/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Biden Administration ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Infrastructure ,
Inversion ,
Legislative Agendas ,
OECD ,
Tax Rates ,
Tax Reform
During the run-up to the November presidential election, then-candidate Joe Biden previewed his tax priorities to enact a more progressive tax code to roll back "giveaways" to wealthy individuals and corporations under the...more
4/9/2021
/ Biden Administration ,
Budget Reconciliation ,
Corporate Taxes ,
Federal Budget ,
Legislative Agendas ,
OECD ,
Parliamentary Procedure ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform