On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...more
5/28/2025
/ Business Development ,
Federal Budget ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
New Legislation ,
REIT ,
Tax Deductions ,
Tax Liability ,
Tax Reform ,
Taxation ,
Ways and Means Committee
On May 14, 2025, the House Ways and Means Committee approved the “One, Big, Beautiful Bill,” containing the tax provisions destined for the budget reconciliation package. Several of the bill’s provisions would affect...more
5/16/2025
/ Filing Requirements ,
Government Agencies ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Proposed Legislation ,
Reporting Requirements ,
Tax Reform ,
Tax Returns ,
Ways and Means Committee
On November 26, 2024, the IRS issued Notice 2024-85, providing a revised timeline for the transition to the $600 threshold in section 6050W(e), as amended by the American Rescue Plan Act of 2021, for third-party settlement...more
Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more
On December 19, 2023, the recently ratified Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal...more
The Internal Revenue Service (the IRS) has provided penalty relief in Notice 2022-36 for certain taxpayers from failure to file penalties and certain international information return penalties with respect to tax returns for...more
The COVID-19 epidemic has resulted in travel restrictions around the globe, and many individuals find themselves stranded outside of the jurisdiction in which they usually work. While individuals may be able to work remotely,...more
As COVID-19 continues to spread around the globe, companies and individuals are facing a diverse and challenging set of issues. These issues span a number of different contexts including tax, and measures are being considered...more
New proposed regulations provide guidelines for alterations to certain interests in real estate mortgage investment conduits (REMICs) and loans held by REMICs to take into account the anticipated phaseout of LIBOR, the...more
On February 4, the IRS issued a new revenue ruling – Rev. Rul. 2014-7 – that indicates that the IRS no longer plans to issue formal guidance concerning the treatment of the dividends-received deduction (DRD) with respect to...more
On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more
12/20/2013
/ Asset Valuations ,
Income Taxes ,
IRS ,
Jurisdiction ,
Material Misstatements ,
Partnerships ,
Penalties ,
SCOTUS ,
Tax Shelters ,
TEFRA ,
Underpayment