On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. The Act is similar to the Senate Finance Committee’s draft legislative text (the “SFC Bill”) (released on June 16, 2025), with...more
On June 17, 2025, the Tax Court opinion in AbbVie Inc. and Subsidiaries v. Commissioner of Internal Revenue was issued, holding that the approximately $1.6 billion termination fee AbbVie (a Delaware corporation) paid to its...more
The One Big Beautiful Bill Act (the “OBBBA“), passed by the U.S. House of Representatives (the “House“) on May 22, 2025, is a comprehensive legislative package that seeks to implement sweeping reforms in tax policy,...more
On Thursday May 22, the House of Representatives passed the One Big Beautiful Bill Act (H.R. 1, hereafter the “Bill”). The Bill will now be considered by the U.S. Senate....more
5/27/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Employee Benefits ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
New Legislation ,
Proposed Legislation ,
SALT ,
Tax Credits ,
Tax Deductions ,
Tax Rates ,
Tax Reform
On May 18, 2025, the House Budget Committee approved the legislation entitled, “The One, Big, Beautiful Bill” (the “House Bill”). The bill is expected to be revised by the House Rules Committee before being sent to the House...more
On January 17, 2025, news sources reported that Republican members of Congress circulated a detailed list of legislative policy options, including tax proposals. This blog post summarizes some of the tax proposals and...more
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 17, 2024, Senate Finance Committee Chairman Ron Wyden (D-Ore.) and House Ways and Means Committee Chairman Jason Smith (R-Mo.) released a bill, the “Tax Relief for American Families and Workers Act of 2024”...more
On March 28, 2022, the Biden Administration released the Fiscal Year 2023 Budget, and the “General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more
7/21/2022
/ Audits ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Bi-Partison Balanced Budget Act (BBA) ,
Biden Administration ,
Budgets ,
Business Taxes ,
Cryptocurrency ,
Digital Assets ,
Donor-Advised Funds (DAFs) ,
FATCA ,
GILTI tax ,
Green Book ,
Loans ,
Mark-To-Market ,
Offshoring ,
Passive Foreign Investment Company ,
REIT ,
Tax Credits ,
Tax Deductions
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 January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or...more
3/11/2019
/ Business Ownership ,
Final Rules ,
IRS ,
Pass-Through Entities ,
Proposed Regulation ,
Qualified Business Income ,
S-Corporation ,
Section 199A ,
Sole Proprietorship ,
Specified Service Trade Or Business (SSTB) ,
Tax Deductions ,
UBIA
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
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more
11/19/2018
/ Borrowers ,
Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
Domestic Corporations ,
Foreign Subsidiaries ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Tax Deductions ,
Tax Exemptions ,
Tax Reform ,
U.S. Treasury
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction" for qualified trade or business income...more
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will...more
1/17/2018
/ Base Erosion Tax ,
Carried Interest ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Taxpayers ,
Income Taxes ,
Pass-Through Entities ,
Tax Cuts and Jobs Act ,
Tax Deductions
The IRS announced yesterday, in IR 2017-210 (the “Advisory”), that state property taxes must be “assessed” in 2017 in order for such taxes to be prepaid in calendar year 2017 and therefore deductible in 2017. The Advisory...more
On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1) (the “Final Bill”), and released legislative text, an explanation, and the Joint Committee...more
12/19/2017
/ 501(c)(3) ,
Affordable Care Act ,
Alternative Minimum Tax ,
Base Erosion Tax ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
EBITDA ,
Excise Tax ,
Income Taxes ,
Individual Mandate ,
International Tax Issues ,
Legislative Agendas ,
Pass-Through Entities ,
PFIC ,
REIT ,
Section 179 Property ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
Tax-Exempt Bonds ,
UBIT
In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more
12/12/2017
/ 401k ,
501(c)(3) ,
501(c)(6) ,
Affordable Care Act ,
Alternative Minimum Tax ,
Base Erosion Tax ,
C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
EBITDA ,
Excise Tax ,
Income Taxes ,
Individual Mandate ,
International Tax Issues ,
Legislative Agendas ,
Pass-Through Entities ,
PFIC ,
Popular ,
Proposed Legislation ,
REIT ,
Section 1031 Exchange ,
Section 179 Property ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
Tax-Exempt Bonds ,
UBIT
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1) (the “House bill”). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10. Late...more
11/20/2017
/ 401k ,
Adjusted Gross Income ,
Affordable Care Act ,
Alternative Minimum Tax ,
Charitable Deductions ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
EBITDA ,
Employee Benefits ,
Excise Tax ,
Foreign Earned Income ,
Foreign Subsidiaries ,
Independent Contractors ,
Individual Mandate ,
IRS ,
New Legislation ,
Pass-Through Entities ,
Personal Property Tax ,
PFIC ,
Popular ,
REIT ,
S-Corporation ,
Section 179 Property ,
Senate Finance Committee ,
Shared Responsibility Rule ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Rates
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
Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump’s original tax reform proposal announced during the campaign and of the House Republicans’...more
In the U.S. general election held on November 8, 2016, Donald J. Trump was elected to become the 45th President of the United States. Republicans also retained their majorities in both the U.S. House of Representatives and...more
11/11/2016
/ Alternative Minimum Tax ,
Business Taxes ,
Estate Tax ,
Income Taxes ,
International Tax Issues ,
Net Operating Losses ,
Presidential Elections ,
Presidential Nominations ,
Research and Development ,
Tax Credits ,
Tax Deductions ,
Tax Policy ,
Tax Rates ,
Tax Reform ,
Trump Administration