News & Analysis as of

Income Taxes Internal Revenue Code (IRC) Internal Revenue Service

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part IX – Deductibility of Automobile Loan Interest

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In this ninth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss provisions of the Act that may permit individual taxpayers to deduct the interest incurred with respect to their...more

Pullman & Comley, LLC

Overview of the Tax Provisions in the One Big Beautiful Bill Act

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On July 4, 2025,, the One Big Beautiful Bill Act (OBBBA) became law.  The Act itself was almost 1,000 pages.  It made many of the provisions of the 2017 Tax Cuts and Jobs Act permanent and included new federal tax provisions....more

Littler

Recent U.S. Tax Court Opinion Illustrates How Language in Settlement Agreements Can Determine Tax Treatment of Payments

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In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more

Whiteford

Employment Law Update: New Overtime Tax Law Increases Employer Recordkeeping Obligation

Whiteford on

The Administration’s “Big Beautiful Bill” includes a new overtime tax provision, broadly described as “No Tax on Overtime.” More accurately, the Bill allows an employee tax deduction of a portion of overtime payments, up to a...more

Mintz - Tax Viewpoints

New Electronic Filing Option for Section 83(b) Elections

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On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

ASKramer Law on

At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more

Holland & Knight LLP

IRS Releases 2025 Inflation Adjustments for Sections 45U, 45V and 45Z

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The IRS on July 21, 2025, released Notice 2025-37, announcing the inflation-adjusted credit amounts for calendar year 2025 applicable to tax credits available under Internal Revenue Code Sections 45U, 45V and 45Z, which were...more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Cadwalader, Wickersham & Taft LLP

House Ways and Means to Crypto’s Rescue on Taxes?

On July 16, 2025, the House Ways and Means Committee held a hearing on crypto taxation. Congress and the Administration did not address tax issues in the most recent Digital Asset legislation, as previously discussed here. ...more

Hanson Bridgett

IRS Clarifies Income Tax Withholding and Reporting Obligations for Uncashed Retirement Checks

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When an employer (or the proper withholding agent, like a plan administrator) issues a retirement benefit, there is generally an obligation to withhold income tax on the payment and to report the payment on Form 1099-R....more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part V – Qualified Small Business Stock Exclusion / Code Section...

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In this fifth installment of my multi-part series on the One Big Beautiful Bill Act, Steve Nofziger and I discuss a provision of the Act that impacts certain business owners who are contemplating a sale of their shares, Code...more

Goodwin

Online Filing of Section 83(b) Elections Is Here!

Goodwin on

Last year, the US Internal Revenue Service (IRS) released Form 15620 for taxpayers to make elections under section 83(b) of the Internal Revenue Code, an important part of US tax planning for founders, employees, board...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

Rivkin Radler LLP

Closely Held Businesses and Their Owners Ask: What’s Big and Beautiful in the Recent Tax Law?

Rivkin Radler LLP on

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

Ballard Spahr LLP

President Trump’s Budget Extends His 2017 Individual Tax Provisions

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President Trump signed into law what is commonly referred to as the One Big Beautiful Bill Act (OBBBA), extending provisions from the Tax Cuts and Jobs Act of 2017 otherwise set to expire at the end of this year. The new...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

It’s Official - No Tax on Tips, No Tax on Overtime Through 2028

One of President Donald Trump’s 2024 campaign messages was a promise to implement a no-tax-on-tips and no-tax-on-overtime law. On July 3, 2025, the U.S. Congress passed the “One Big Beautiful Bill,” and President Trump signed...more

Schwabe, Williamson & Wyatt PC

U.S. Treasury Announces Tribal Consultation on General Welfare Exclusion Act

On June 30, 2025, the United States Department of the Treasury announced that it will be holding an online tribal consultation with Alaska Native Corporations on July 29, 2025, from 1:30 pm to 4:30 pm ET, to discuss the...more

Holland & Knight LLP

AbbVie's Tax Triumph: Breaking Free from Capital Loss Limitations

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In a significant win for taxpayers, the U.S. Tax Court recently ruled in AbbVie Inc. v. Commissioner, Docket No. 2597-23, that a $1.6 billion "Break Fee" paid by AbbVie qualifies as an ordinary and necessary business expense...more

Cadwalader, Wickersham & Taft LLP

Congress Targets Partnership Disguised Sales and Services

Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more

Hone Maxwell

Supreme Court Gives IRS Ability to Levy Taxpayers Without Tax Court Challenge

Hone Maxwell on

In a pivotal ruling, the U.S. Supreme Court on June 12, 2025, held that the U.S. Tax Court lacks jurisdiction to hear a taxpayer’s Collection Due Process appeal under IRC § 6330 once the IRS can no longer pursue a levy,...more

Pillsbury Winthrop Shaw Pittman LLP

Parallel Play: The U.S. Senate Finance Committee Releases Its Version of the “Big, Beautiful Bill”

When toddlers engage in parallel play, the children play adjacent to each other, but do not try to influence one another’s behavior. Apparently, parallel play can extend well into adulthood and to the writing of federal...more

McDermott Will & Schulte

Potential Refund Opportunity for Interest and Penalty Amounts Accrued During COVID-19 Federally Declared Disaster

Taxpayers who made payments to the Internal Revenue Service (IRS) that included underpayment interest and/or failure-to-file/pay penalties that accrued during all or part of the period between January 20, 2020, through July...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

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Husch Blackwell LLP

U.S. Tax Court Rules That Limited Partners of an Investment Manager Are Subject to Self-Employment Tax

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On May 28, 2025, the United States Tax Court held that the limited partners of a limited partnership providing investment management services to various investment funds were not limited partners within the meaning of...more

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