The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Impuesto de Timbre: Cuantía indeterminada
Podcast - Betty… ¿y si nos vamos a la reorganización?
Impuesto de Timbre, ¿otra vez?
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
Year-End and Trending Tax Considerations for Health Care Practices
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
Podcast - La Prima por Fusión
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing
10 Things Lawyers Should Know About BVI Transactions
Tax Planning Under a Biden Presidency
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Tax Provisions in Business Acquisition Agreements
On July 4, 2025, President Trump signed into law the legislation commonly referred to as the One Big Beautiful Bill or OBBBA, which includes several changes to the federal income tax treatment of trade or business activities....more
In this fourth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), Steve Nofziger and I discuss a provision of the Act that impacts pass-through business entities and their owners, Code Section...more
The “One Big Beautiful Bill Act” (the “Act”) was signed into law last week, on July 4. As promised by the White House, the Act extends – i.e., purports to make “permanent” – many of the otherwise expiring provisions that were...more
On November 29, 2024, the United States Internal Revenue Service (the “IRS”) released final regulations (Final Regulations) relating to the allocation of recourse partnership liabilities under section 752 of the Internal...more
Join Williams Mullen for our hybrid 2025 Winter Tax Forum on Thursday, February 6th. Our speakers, Anna Derewenda, Kyle Wingfield, Kevin Bender, and Patrick Carr will provide an update on the following: - New Basis...more
Many senior housing properties are owned by limited liability companies or other entities that are taxed as partnerships for federal income tax purposes. The March 15th deadline for filing federal partnership tax returns is...more
On December 8, Treasury issued final regulations (the “Final Regulations”) updating the existing centralized partnership audit regime. These regulations largely adopt the provisions of regulations that were previously...more
Partnership Formation - The formation of a partnership is generally a nonrecognition transaction for both the contributing partner and the newly-created partnership. Thus, as a general rule, no gain is recognized by a...more
On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more
As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more
The Tax Gene? King of Swamp Castle: One day, lad, all this will be yours. Prince Herbert: What, the curtains? King: No, not the curtains, lad. I’m talking about all of my business and investment interests, along with...more
Earlier this week, a local tax practitioner asked us whether it was true that the City of Portland no longer allows depreciation deductions resulting from an election under Section 754 of the Internal Revenue Code of 1986, as...more
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
Due to the significant changes to the Internal Revenue Code (“Code”) made by the Tax Cuts and Jobs Act (“Tax Act”) at the end of last year, the Department of the Treasury has been very busy issuing guidance and proposed...more
New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more
The IRS has issued Proposed Regulations now under the new Section 199A 20% profit deduction for pass-through entities. The Proposed Regulations provide important guidance on the definition of “Qualified Business Income” –...more
The Internal Revenue Service yesterday issued its much-anticipated Proposed Regulations on the new Section 199A 20% deduction for owners of pass-through business entities. This important deduction was created under the 2017...more
The Service issued proposed regulations corresponding to IRC § 199A yesterday. As discussed in a prior blog post, IRC § 199A potentially allows individuals, trusts and estates to deduct up to 20% of qualified business income...more
Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more
“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more
The new Tax Cut and Jobs Act of 2017 (the “Act”) contains a provision that is of great importance to any persons buying or selling an interest in a partnership. New Section 864(c)(8) of the U.S. Internal Revenue Code (the...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more
On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more
It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more