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Internal Revenue Service Tax Reform Tax Liability

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

Section 1202 and QSBS: A Survey of States That Don’t Conform to the Federal Treatment

Frost Brown Todd on

Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more

Patterson Belknap Webb & Tyler LLP

The One Big Beautiful Bill: Top Tax Takeaways for Nonprofits

President Trump’s sweeping package of domestic legislation, H.R. 1 (originally titled the One Big Beautiful Bill Act (the “OBBB”)), became law on July 4, 2025. In addition to dramatically reshaping the landscape for...more

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Amendments to the Excise Tax Imposed on Certain Private College and University...

Troutman Pepper Locke on

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). This legislation includes significant amendments to the excise tax imposed on...more

BakerHostetler

[Podcast] An Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

Troutman Pepper Locke on

On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...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

Eversheds Sutherland (US) LLP

House tax bill proposes major changes to the Employee Retention Tax Credit (ERTC)

On May 12, 2025, the Republicans on the House Committee on Ways and Means introduced a broad tax reform bill that includes sweeping changes to the Employee Retention Tax Credit (ERTC), also commonly known as the ERC. Chief...more

Cadwalader, Wickersham & Taft LLP

DeFi Off the Hook for Crypto Tax Reporting

Congress and President Trump have provided legislative relief to decentralized crypto exchanges (and DeFi protocols) from the tax reporting obligations applicable more generally to crypto ‘brokers.’ On April 10, President...more

McDermott Will & Schulte

IRS Roundup February 17 – March 14, 2025

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

Amundsen Davis LLC

No Tax on Tips Act: How Taxpayers Can Prepare

Amundsen Davis LLC on

Tipping has been part of the modern-day American restaurant experience for decades. Like most forms of income, these tips are taxable and subject to income tax. But what if this income was free from income tax liability?...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 3, 2025

Tax developments - The validity of the 245A DRD for indirectly owned foreign corporations - On January 21, 2025, the IRS filed a motion for summary judgment asking the Tax Court to hold that Sysco Corporation (Sysco)...more

Husch Blackwell LLP

Impending IRS Workforce Cuts Mean Taxpayers Should Act Now to Resolve IRS Issues

Husch Blackwell LLP on

The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more

Proskauer - Tax Talks

Senators Crapo and Wyden Release Draft Bipartisan Taxpayer Rights Legislation

Proskauer - Tax Talks on

On January 30, 2025, Mike Crapo (R-ID), the Chairman of the Senate Finance Committee, and Senator Ron Wyden (D-OR), the Ranking Member of the Senate Finance Committee released a discussion draft of the “Taxpayer Assistance...more

McDermott Will & Schulte

IRS Roundup February 10 – 14, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS - The previous IRS...more

Fox Rothschild LLP

IRS Layoffs May Mean Longer Waits, Audit Delays and Tax Court Battles

Fox Rothschild LLP on

The Internal Revenue Service (IRS) is expected to lay off approximately 7% of its workforce in the coming weeks, with the possibility of further reductions. It remains unclear which divisions will be most affected or whether...more

Seward & Kissel LLP

Section 883 Tax Exemption for Cargo Shipping and Cruise Lines At Risk?

Seward & Kissel LLP on

Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more

Greenberg Glusker LLP

How about: Shifting Tax Strategies: What Businesses Need to Know for 2025

Greenberg Glusker LLP on

Corporate & Tax Partner Michael Wiener shared his expertise on how businesses, CFOs, and financial professionals are adapting to the evolving economic landscape and shifting tax strategies with the Los Angeles Business...more

Eversheds Sutherland (US) LLP

SALT Scoreboard - Quarter 4, 2024

This is the fourth edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more

Allen Barron, Inc.

Will You Recognize the Form 1099-K When You Receive it This Year?

Allen Barron, Inc. on

Will you recognize the Form 1099-K when you receive it from one or more third-party marketplace providers this year?  A few years ago, the IRS implemented new reporting requirements for many popular peer-to-peer payment apps...more

Bradley Arant Boult Cummings LLP

Not Cool, Man: Senate Proposal to Expand 280E Taxes on Cannabis Businesses Even if Rescheduled

Anyone who thought that the momentum towards federal liberalization of marijuana would be a straight line found themselves with a cold dash of water to the face. Late last week Republican senators filed a bill, entitled the...more

Goodwin

Fiscalité des « management packages »

Goodwin on

La loi de finances pour 2025 prévoit l’instauration d’un régime fiscal et social spécifique pour les gains réalisés par les managers à raison des participations qu’ils détiennent dans les groupes dans lesquels ils exercent...more

Seward & Kissel LLP

Carried Interest in the Crosshairs…Again

Seward & Kissel LLP on

On February 6, 2025, Democratic Senators and Representatives proposed the Carried Interest Fairness Act, which would treat carried interest as ordinary income. Additionally, on the same day President Trump met with...more

Troutman Pepper Locke

IRS Issues Proposed Regulations on the Expanded Definition of "Covered Employee" Under Code Section 162(m)

Troutman Pepper Locke on

On January 16, the Internal Revenue Service (IRS) published proposed regulations ( 90 FR 4691) under Section 162(m) of the Internal Revenue Code. Section 162(m) generally limits the deductibility of compensation paid in any...more

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....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

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