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Mayer Brown

What the New Remittance Transfer Excise Tax Means for Businesses

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OVERVIEW OF THE REMITTANCE TRANSFER EXCISE TAX - Do you effect transfers of funds for US residents to recipients abroad? If so, you should review the provision of the “One Big Beautiful Bill Act” (“OBBBA”) that imposes a...more

DLA Piper

One Big Beautiful Bill Act: Top Points for the Investment Funds Industry

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President Donald J. Trump signed the legislation commonly known as the “One Big Beautiful Bill” (Tax Act) into law on July 4, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management...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

DLA Piper

REIT Tax News - June 2025

DLA Piper on

On May 22, 2025, the House of Representatives passed a tax bill (House Tax Bill) that proposes to make permanent – and increase – the section 199A deduction for ordinary REIT dividends to 23 percent. This change would reduce...more

Proskauer - Tax Talks

Senator Tillis Introduced a Bill Taxing Proceeds of Litigation Financing Agreements

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Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more

Pillsbury Winthrop Shaw Pittman LLP

Norwich v. Comm’r: Private Credit Firm Prevails in Tax Dispute to Reverse Over-Reported Income

In Norwich v. Comm’r, the taxpayer mistakenly received $7.5 million[2] as a result of various bank errors between 2007 and 2014. Not knowing that the cash was incorrectly released to it, the taxpayer reported those amounts as...more

Frost Brown Todd

TEFRA Approvals: Considerations for Officeholders When Approving Private Activity Bonds

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New officeholders often ask us to clarify their responsibilities when it comes to public approval of bonds and the consequences for states and their political subdivisions when they approve bonds as tax-exempt. What follows...more

Vinson & Elkins LLP

Congress Begins Taking Action to Nullify Biden-Era Tax Regulations

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The opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in...more

Freeman Law

House Says No to Crypto Reporting Regs

Freeman Law on

On March 11, 2025, the United States House of Representatives passed a joint resolution to overturn a rule that the IRS had promulgated regarding “Gross Proceeds Reporting by Brokers That Regularly Provide Services...more

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

Womble Bond Dickinson on

Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Cadwalader, Wickersham & Taft LLP

Finalized Treasury Regulations Require Disclosure of Certain Micro-captive Transactions

On January 14, 2025, Treasury and the IRS published final regulations (the “Regulations”) that identify certain micro-captive insurance transactions, as well as transactions substantially similar thereto, as either listed...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Dickinson Wright

If the Deadline for Self-Correcting Retirement Plan Errors Is Indefinite, Why Do I Have to Hurry?

Dickinson Wright on

Section 305 of SECURE 2.0 added rules for self-correcting a new category of retirement plan errors under the Employee Plans Compliance Resolution System (“ECPRS”). Specifically, Section 305 allows an “eligible inadvertent...more

Carlton Fields

The DOL Fiduciary Rule Is Here – Are You an Investment Advice Fiduciary?

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The Department of Labor’s final definition of “investment advice” fiduciary regulation makes many more individuals fiduciaries under both the Employee Retirement Income Security Act and the Internal Revenue Code. Where for...more

Nelson Mullins Riley & Scarborough LLP

Death, Taxes, and Crypto Reporting – The Three Things You Cannot Escape

The IRS released a draft of Form 1099-DA “Digital Asset Proceeds from Broker Transactions” in April which will require anyone defined as a “broker” to report certain information related to the sale of digital assets. The new...more

McCarter & English, LLP

DEA’s Plan to Reschedule Cannabis: Implications and Insights

Earlier this week, the Department of Justice proposed reclassifying cannabis from Schedule I to Schedule III under the Controlled Substances Act. The move follows an August 2023 recommendation from the Department of Health...more

Carlton Fields

DOL Releases New Fiduciary Rule, Broadens Definition of Investment Advice Under ERISA

Carlton Fields on

On April 23, 2024, the Department of Labor published its long-awaited final retirement security rule broadening the definition of who is an “investment advice fiduciary” under section 3(21) of the Employee Retirement Income...more

Troutman Pepper Locke

How Can I Claim a Business Bad Debt Deduction? - Creditor's Rights Toolkit

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The Internal Revenue Code permits a business bad debt deduction when a customer fails to pay for the services rendered or the products supplied by your business. However, the ability to claim an ordinary deduction with...more

Seward & Kissel LLP

FinCEN Proposes New Rule to Subject Advisers to AML Requirements

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Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...more

Cadwalader, Wickersham & Taft LLP

ABA Tax Section Comments on Proposed Crypto Broker Reporting Regulations

On December 20th, 2023, the American Bar Association Tax Section published detailed comments and recommendations (the “ABA Comments”) on the proposed crypto broker reporting regulations.  As discussed here, the New York State...more

Cadwalader, Wickersham & Taft LLP

A Worthwhile Proposal for Worthless Debt

In December, Treasury and the IRS issued proposed regulations updating the standard for determining when a debt instrument held by certain banks and insurance regulated entities will be conclusively presumed to be worthless...more

Cadwalader, Wickersham & Taft LLP

Treasury Cries “Uncle” to Crypto Industry: Crypto Reporting Delayed

On January 16th, the IRS published Announcement 2024-4 (the “Announcement”), postponing certain reporting requirements for large crypto transactions which were set to go into effect for the 2024 tax year.  Persons engaged in...more

Troutman Pepper Locke

Navigating Cryptocurrency in the Marijuana Industry: Risks and Technological Solutions

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The marijuana industry has seen exponential growth over the past few years. However, the federal prohibition of marijuana poses significant challenges for businesses in this sector, in terms of payment processing and banking....more

Stinson - Benefits Notes Blog

Annual Limits on Qualified Plans for 2024

On November 1, 2023, the Internal Revenue Service (IRS) released Notice 2023-75, which sets forth the 2024 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The...more

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