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
7/21/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Budget Reconciliation ,
Congressional Committees ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EU ,
G7 ,
GILTI tax ,
International Tax Issues ,
IRS ,
Multinationals ,
OECD ,
Public Policy ,
Tax Cuts and Jobs Act ,
Tax Legislation ,
Tax Reform ,
US Trade Policies
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
7/8/2025
/ Corporate Taxes ,
Employee Benefits ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Mortgage REITS ,
Opportunity Zones ,
Popular ,
Qualified Small Business Stock ,
Research and Development ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Legislation ,
Tax Reform ,
Trump Administration
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
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
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
2/13/2013
/ Due Diligence ,
FATCA ,
FFI ,
Foreign Banks ,
Foreign Financial Accounts ,
Form W-8 ,
Form W-9 ,
Intergovernmental Agreements ,
Investment Firms ,
IRS ,
Withholding Requirements
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