5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
The Demystification of Employee Retention Credits for Private Equity Deals — PE Pathways Podcast
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
What is Reverse Vesting and What are the Tax Considerations?
What's the Best Transaction Structure for My Sale?
Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
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
The qualified small business stock (QSBS) rules can be a powerful tax planning tool, and, following the recent enactment of a signature tax law, they have become even more potent....more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA), which both extends many soon-to-expire provisions of the Tax Cuts and Jobs Act of 2017 (TCJA) and makes several additional changes to the...more
On July 4, 2025, the One Big Beautiful Bill Act (the “OBBB”) was signed into law, introducing a broad package of policy reforms, funding reallocations, and regulatory changes set to reshape the nation’s infrastructure,...more
On July 4, 2025, the legislation commonly known as “The One Big Beautiful Bill Act” (the “BBBA”) was enacted. The BBBA makes permanent, extends and, in certain cases, modifies, a number of provisions from the 2017 Tax Cuts...more
On May 22, 2025, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA), which includes a temporary suspension of the amortization requirement for domestic research and experimentation (R&E)...more
On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more
On May 12, 2025, the Republicans on the House Committee on Ways and Means released a draft bill showing their tax plan for the budget reconciliation legislation. The legislation will likely undergo significant changes as it...more
President Trump used his 4 March 2025 address to the joint session of Congress to remind the American public and Congressional leaders that he is serious about adding his imprimatur to the tax code—and in the process adding...more
Corporate & Tax Partner Michael Wiener shared his expertise on how businesses, CFOs, and financial professionals are adapting to the evolving economic landscape and shifting tax strategies with the Los Angeles Business...more
A potential refund opportunity under the Michigan corporate income tax may justify taking action before year end. The issue concerns the Michigan Department of Treasury’s position that the Internal Revenue Code (“IRC”) 163(j)...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 22, 2024 – July 26, 2024....more
What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more
On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more
On February 21, 2024, the Internal Revenue Service (IRS) announced plans to commence a focused audit effort targeting private aircraft usage by dozens of large corporations, large partnerships and high-income individual...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 22, 2024 – January 26, 2024....more
Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more
Hobby Loss or Business Loss Tax Deduction - It’s not every day that a case comes through the Tax Court centered on the taxation of miniature donkey breeding. But the recent case of Huff v. Commissioner was focused on just...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
Although Oregon’s 2021 legislative session turned out to be relatively quiet from a tax perspective, we did experience some changes to Oregon’s Corporate Activity Tax (“CAT”). Those changes were primarily in the form of SB...more
One of the most important decisions a board determines is what constitutes reasonable compensation. The rules for this determination are robust and so are the taxes imposed for violations of the Internal Revenue Code and the...more
It is not unreasonable to anticipate that there will be a federal tax policy transformation following a change in the political control of the White House, the U.S. Senate and the U.S. House of Representatives. What may be...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
On April 9, 2020, the IRS issued: Rev. Proc. 2020-24, which provides guidance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) relating to relinquishment of certain net operating loss (NOL)...more
On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more