News & Analysis as of

Internal Revenue Service Exclusions Tax Planning

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Frost Brown Todd

One Big Beautiful Bill Act Enacts a Permanent Increase in the Estate and Gift Tax Lifetime Exclusion Amount for 2025 and Later...

Frost Brown Todd on

On July 3, 2025, and by a vote of 218 to 214, the U.S. House of Representative passed the Senate’s amended version of H.R. 1 (also known as the “One Big Beautiful Bill Act” or OBBBA 2025), which is the tax-and-budget...more

DarrowEverett LLP

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

DarrowEverett LLP on

In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

Kohrman Jackson & Krantz LLP

Limited in Name but Not in Tax? U.S. Tax Court Increases Tax Liability for Limited Partners

Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more

Bilzin Sumberg

Inflation Adjustments for 2024: Key Information for International Private Client Practitioners

Bilzin Sumberg on

The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more

Woods Rogers

‘Tis the Season (For Charitable Giving)

Woods Rogers on

The year-end is approaching, but you still have time to work on your 2022 tax planning. Consider giving to your favorite charity to make this holiday season merry. Planned charitable giving provides you a way to maximize...more

McDermott Will & Emery

Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base

McDermott Will & Emery on

On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base...more

Chambliss, Bahner & Stophel, P.C.

Top 5 Tax Considerations Related to Your Estate Planning

It's time to start the conversation with your tax advisor. The 2019 filing deadline is Monday, April 15. Note the new tax brackets. The new law imposes a new tax rate structure with seven tax brackets for 2018: 10%, 12%, 22%,...more

Burr & Forman

Tax Reform and Estate Planning: How the 2017 Tax Cuts and Jobs Act Impacts Estate Plans for McNair Clients

Burr & Forman on

When the 2017 Tax Cuts and Jobs Act was passed, significant changes were made to the Federal Estate, Gift and Generation-Skipping Transfer Tax, the most prominent of which is the increased applicable exclusion amount, which...more

Foodman CPAs & Advisors

“File before the IRS discovers that you failed to choose the Exclusion”: words of wisdom to US Taxpayers Living Abroad

If you are a US citizen or a Permanente Resident and you live abroad, you are taxed on your worldwide income and you are considered a US Taxpayer. ...more

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