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Financial Institutions Income Taxes

Littler

Employers May Offer a New Benefit Through “Trump Accounts”

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The One Big Beautiful Bill Act (OBBBA), which was signed into law on July 4, 2025, establishes the pilot program for the “Trump account,” an investment account for U.S. citizens under age 18 with a social security number....more

Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

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In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Fox Rothschild LLP

Changes in Washington State Tax Law Will Impact Businesses

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Washington recently enacted major tax law changes that will affect many businesses operating in the state. Here’s what you need to know: Changes to the Definition of Incidental Investment Income - Washington law now...more

Seward & Kissel LLP

Proposed Tax on Certain Outbound Remittances

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In just under two weeks, the House of Representatives introduced, modified and passed the One Big, Beautiful Bill of 2025 (the “House Tax Bill”). This Memorandum addresses a new proposed tax on certain persons sending money...more

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

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Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more

Pillsbury Winthrop Shaw Pittman LLP

California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment formula for financial institutions, aiming to increase tax revenue starting in tax year 2025. Update: On May 14, 2025, Governor Newsom released the May...more

Pillsbury Winthrop Shaw Pittman LLP

California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more

Mayer Brown

Exploring the Unexpected and Often Unwelcome Federal Income Tax Consequences of Debt Modifications

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As a number of debt instruments issued several years ago in a relatively low interest rate environment now have their maturity date approaching in a much higher interest rate environment, borrowers are increasingly seeking to...more

Seward & Kissel LLP

Greenbook Tax Proposals

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Tax reform, like spring, is in the air. The Biden Administration recently released its fiscal year 2025 revenue proposals, known as the annual “Greenbook.” The Greenbook’s 250+ pages of tax reforms include six potential...more

Cadwalader, Wickersham & Taft LLP

UK Spring Budget 2024

Key Tax Measures The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Spring Budget for 2024 on 8 March, 2024.  The Budget was delivered against the backdrop of an anticipated general election in the summer...more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

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In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Blake, Cassels & Graydon LLP

Présentation de certaines mesures fiscales prévues dans le projet de loi C-59 du Canada

Points saillants - Le 28 novembre 2023, le ministère des Finances (le « ministère ») a déposé un avis de motion de voies et moyens visant à mettre en œuvre la Loi d’exécution de l’énoncé économique de l’automne 2023, qui a...more

Blake, Cassels & Graydon LLP

Select Tax Measures in Canada’s Bill C-59

Highlights - On November 28, 2023, the Department of Finance (Finance) tabled a Notice of Ways and Means Motion to implement the Fall Economic Statement Implementation Act, 2023, which subsequently received first reading...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Makes Permanent Its Fast-Track Corporate Private Letter Rulings

On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more

Blake, Cassels & Graydon LLP

Budget fédéral de 2022 – Présentation de certaines mesures fiscales

Le 7 avril 2022 (le « jour du Budget »), la ministre des Finances du Canada a présenté le budget fédéral de 2022 (le « Budget 2022 »). Certains contribuables ont peut-être été soulagés de constater que le Budget 2022 ne...more

Blake, Cassels & Graydon LLP

2022 Federal Budget: Selected Tax Measures

On April 7, 2022 (Budget Day), the Minister of Finance introduced Canada’s 2022 Federal Budget (Budget 2022). While taxpayers may be relieved that Budget 2022 does not include an increase to the capital gains inclusion rate...more

Hogan Lovells

With a New Year, Brings a New Rate . . . The Transition from LIBOR Is Now Here

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In March 2021, the Financial Conduct Authority (FCA) and the ICE Benchmark Administration, the administrator of LIBOR, announced that sterling, euro, Swiss franc and Japanese yen LIBOR panels, as well as panels for one-week...more

Foodman CPAs & Advisors

Cómo las Administraciones Tributarias Manejan el Incumplimiento de FATCA, CRS

Las administraciones tributarias pueden utilizar una combinación de medidas de detección, preventivas y correctivas para evaluar y tratar Ley de Cumplimiento Tributario de Cuentas Extranjeras (FATCA) y el incumplimiento del...more

Foster Garvey PC

The Washington State Supreme Court Renders a Decision Impacting Financial Institutions Doing Business in the State

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On September 30, 2021, the Washington State Supreme Court upheld the constitutionality of the additional 1.2 percent business and occupation (B&O) tax imposed by the 2019 Substitute House Bill 2167 (“SHB 2167”) on “specified...more

Foodman CPAs & Advisors

2021 “Green Book” Introduces Comprehensive Financial Account Reporting

The “Green Book” is a US Treasury Department document that presents detailed explanations of an Administration’s revenue proposals in support of a President’s annual budget request.  On May 28, 2021, the Biden administration...more

Foodman CPAs & Advisors

The Tax Gap To Rise To Approximately $7 Trillion

The US Treasury reports that it is expecting the tax gap to rise to approximately $7 trillion over the course of the next decade if left unaddressed.   In May 2021, the US Department of the Treasury issued the “THE AMERICAN...more

Bowditch & Dewey

Cryptocurrency Tax Update

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The IRS continues its campaign against cryptocurrency investors and traders who evade income taxes on currency gains. As we wrote in 2016, the IRS was successful in compelling Coinbase, a large digital currency exchange, to...more

Foley & Lardner LLP

Biden Administration Proposes Financial Surveillance Regime Likely to Catch Tax-Dodging Small Business Owners

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Under present law, most Americans’ taxable income is reported by both the payor and the payee. Wage income is reported by the employer on a form W-2 and by the employee on an annual tax return. Independent contractor income...more

Bradley Arant Boult Cummings LLP

ADOR Affirms Deductibility of PPP Loan-Related Expenses but Unanswered Conformity Questions Remain

The Alabama Department of Revenue issued helpful guidance on January 7, following its December 18, 2020 guidance implementing Governor Ivey’s landmark Supplemental Emergency Proclamation. The new guidance affirms the...more

Jones Day

Italy: 110% Tax Deduction Enacted for Certain Energy and Anti-Seismic Works on Existing Buildings

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The Situation: For years, the Italian tax system has provided for certain tax deductions from income taxes in case of building restoration works. The Result: The tax deduction from income taxes has now been increased to...more

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