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Downs Rachlin Martin PLLC

Captive Insurance Update | Issue 2 | 2025

Every year, the members of the Vermont Captive Insurance Association’s legislative committee and the Vermont Department of Financial Regulation (the “DFR”) work to improve Vermont’s captive insurance laws and regulations....more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of July 14, 2025

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

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part III – Gambling / Code Section 165(d)

Foster Garvey PC on

In this third installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss a provision of the Act that may not impact a large segment of the population, but which is interesting and worthy of...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Issue 1 | 2025

Every year, the members of the Vermont Captive Insurance Association’s legislative committee and the Vermont Department of Financial Regulation (the “DFR”) work to improve Vermont’s captive insurance laws and regulations....more

McDermott Will & Schulte

Microsoft Scores Massive Win in California, Opens the Door for Others Nationwide

The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more

Rivkin Radler LLP

Sale of Mortgaged Property – Amount Realized or COD Income

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Do you feel as challenged as I do when someone asks you to explain the term “Bidenomics”? I know that it is predicated upon the imposition of higher taxes on businesses and their owners, which have not yet materialized....more

McDermott Will & Schulte

Extending the Statute of Limitations for Assessing Federal Tax

We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

Rivkin Radler LLP

Employee-Shareholders, Reasonable Compensation And Employment Taxes

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Movement Toward Tax Increases- You may have read last week that Democrats on the Senate Budget Committee announced they had reached a deal on a budget resolution that will enable them to bypass Senate Republicans on the...more

Freeman Law

The Tax Court in Brief - June 2021 #2

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of June 21 – June 25, 2021 - Ervin v. Commissioner, T.C....more

Farrell Fritz, P.C.

Corporate Tax Hike On The Horizon: Using Reasonable Compensation To Withdraw Value

Farrell Fritz, P.C. on

Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...more

Freeman Law

The Tax Court in Brief - February 2021 #2

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of February 8 – February 12, 2021 - BM Construction v....more

McDermott Will & Schulte

Weekly IRS Roundup June 1 – June 5, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 1 – June 5, 2020... June 2, 2020: The IRS reminded taxpayers who live and work abroad that...more

Morrison & Foerster LLP

Amazon Prevails in Ninth Circuit – Government Opportunism Rejected

Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon’s victory in a major transfer pricing dispute. The decision is also a victory for taxpayers generally because of the Ninth Circuit’s...more

Morrison & Foerster LLP

Total Buyout & Copyrights – Highest German Tax Court Confirms Application of German Withholding Tax

The German Federal Fiscal Court (BFH) Confirms That Total Buyout Agreements Regarding Copyrights Are Subject to German Withholding Tax - OVERVIEW - Under German tax law, remunerations paid abroad by persons/companies...more

Holland & Knight LLP

Takeaways from the Tax Court's First Micro-Captive Insurance Ruling

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• The U.S. Tax Court recently ruled in Avrahami v. Commissioner, the first litigated Tax Court case involving an 831(b) captive insurance company. • The Tax Court held that two of the key factors that define "insurance"...more

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