Taxing Intelligence: AI's Role in Modern Tax Administration
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
Navigating Contractor vs. Employee Classification
Insider Transaction Traps for the Unwary
Multijurisdictional Employers, Part 1: Independent Contractors vs. Employees
The Presumption of Innocence Podcast: Episode 60 - Enforcement Priorities of the Second Trump Administration: Employee Retention Tax Credit
REFRESH Steps for Launching a New Charitable Corporation
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
Are Overtime Wages and Tips Exempt From Income Tax? What Employers Need to Know to Prepare
Nonprofit Basics: IRS 10-Course Charity Workshop
Nonprofit Basics: Unrelated Business Income Tax: Debt Financed Income - Part 3
The Demystification of Employee Retention Credits for Private Equity Deals — PE Pathways Podcast
Nonprofit Basics: Unrelated Business Income Tax: Modifications and Exceptions - Part 2
Navigating the Inflation Reduction Act: Insights on Brownfield Energy Community Credits - Energy Law Insights
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
REFRESH Nonprofit Basics: Year-End Thoughts and New Year To-Do List
What's the Best Transaction Structure for My Sale?
Year-End and Trending Tax Considerations for Health Care Practices
Nonprofit Basics: International Grantmaking – Part 2 Income Tax Withholding Rules
PODCAST: Williams Mullen's Benefits Companion - Tax Relief and Possible Retirement Plan Resources for Hurricane Victims
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
Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more
The global tax enforcement landscape is progressing rapidly, driven by regulatory changes, increasing cross-border collaboration, and shifts in funding for key tax authorities. Businesses operating in multiple jurisdictions...more
The United States and Canada are each other’s largest trade partners with nearly C$3.6 billion/US$2.7 billion worth of goods and services crossing the border each day in 2023. The United States is the single greatest...more
Imagine a Canadian company adopts a deferred share unit plan (DSU Plan) for its directors. At the time the plan is adopted, the company does not have the plan reviewed by U.S. counsel, because none of their directors reside...more
In our blog post dated August 22, 2022, we discussed the one percent (1%) excise tax on certain stock repurchase transactions by certain publicly traded corporations enacted as part of the Inflation Reduction Act of 2022 (the...more
There have been some interesting developments of late with respect to the ownership of real property in parts of the English-speaking world. For example, Canada has imposed a temporary ban on the purchase of such property by...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by certain...more
In transactions in which a Canadian corporation seeks to acquire a U.S. target entity for shares of the Canadian acquiror in a transaction intended to be tax-deferred for U.S. federal income tax purposes, the ability of U.S....more
Canadian persons and entities owning a significant interest in a U.S. corporation or U.S. entity classified as a “disregarded entity” for U.S. federal income tax purposes should ensure they are compliant with IRS Form 5472...more
Current closures at the Internal Revenue Service (“IRS”) have caused significant delays in obtaining an Employer Identification Number (“EIN”) for some U.S. businesses formed by Canadians, including new U.S. subsidiaries...more
COVID-19 continues to dominate the news – no surprise there. Whether it’s federal relief or state legalization roadblocks, the virus is everywhere. But there is some other news: the IRS seems likely to increase auditing of...more
As Covid-19 continues to spread, many countries, including the United States and Canada, are increasingly closing their borders in an attempt to slow the rate of infection. This precaution may, however, have unintended tax...more
To cap or not to cap, that was the question facing the state of Florida this week. Lawmakers wrestled with the issue of capping THC content in medical marijuana for those patients under the age of 21. The Senate Rules...more
U.S. Developments - Regulatory Developments - SEC and FINRA Issue Joint Statement on Digital Asset Custody Issues - On July 8, 2019, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry...more
British lawmakers are voting today on Theresa May’s updated Brexit plan, and by all accounts, it’s been a mad dash for the Prime Minister in recent weeks to shore up support for a plan “that could go down to a humiliating...more
On the heels of the European Union's General Data Protection law, which went into effect in May 2018, California has enacted the California Consumer Privacy Act ("CCPA")—the result of an 11th-hour compromise between...more
More on the rather shocking departure of John Flannery from GE, the Board that didn’t want to give him any more leash for his turnaround plans, and the future of the embattled corporate giant under Larry Culp....more
JONES DAY CYBERSECURITY, PRIVACY & DATA PROTECTION ATTORNEY SPOTLIGHT: Richard Martinez - Europe's new General Data Protection Regulation ("GDPR") is driving an evolution in corporate privacy practices globally. As...more
FINAL CANADIAN BAIL-IN RULES: IMPACT ON STRUCTURED NOTES OFFERED IN THE UNITED STATES - In March 2018, the Canadian government released its final regulations relating to “bail-in instruments” issued by Canadian...more
As of January 1, 2013, United States banks were required to report to the IRS interest earned by nonresident aliens who are residents of certain foreign countries. The reporting requirement previously existed for accounts...more