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Analysis of International Tax Changes Under the 2025 Tax Legislation

The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more

Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more

Per-Account or Per-Form Penalty?

Key Takeaways: ..The law regarding computation of FBAR penalties is unclear. ..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts. ..Until the Supreme Court...more

IRS Publishes Proposed Regulations Addressing Fracking Services by MLPs

On May 6, 2015, the Internal Revenue Service (IRS) published proposed regulations [REG-132634-14], which if finalized would clarify that income from certain oil and natural gas fracturing (“fracking”) services is “qualifying...more

Highlights of Recently Released FATCA Regulations

On January 17, the Internal Revenue Service issued long-awaited final regulations (the Final Regulations) for implementing the Foreign Account Tax Compliance Act (FATCA) (the Final Regulations are contained in T.D. 9610). For...more

Sixth Circuit Denies Government Motion for Rehearing in Quality Stores Employment Tax Challenge

The Sixth Circuit has unanimously and summarily denied a Government request for en banc rehearing of a taxpayer-favorable ruling in United States v. Quality Stores, Inc., 693 F.3d 605 (6th Cir. Sept. 7, 2012)....more

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