News & Analysis as of

Jurisdiction Tax Planning

Jackson Walker

One Big Beautiful Bill Act Increases Deduction for State and Local Tax but Fails to Address Nexus Concerns

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In welcome news for individual taxpayers, the One Big Beautiful Bill Act temporarily increases the “SALT cap” – the limit on the amount of the income tax deduction for state and local income, sales, and property taxes – from...more

Hone Maxwell

Cross-Border Collaboration Success: Five Top Strategies

Hone Maxwell on

In the United States, we drive on the right side of the road. In Singapore, cars drive on the left. Mexico, meanwhile, has its own road signs and speed limits, which sometimes are viewed as suggestions....more

Walkers

The future of family offices: Evolving needs, enduring structures

Walkers on

Across the globe, second and third generations are inheriting significant wealth and with it, the opportunity to professionalise how their family manages, governs and grows that wealth. Many are establishing dynamic,...more

Offit Kurman

Two Wills That Revoke Each Other

Offit Kurman on

Welcome to Lost in Translation: Blunders in International Estate Planning; in this blog series, I will delve into the rarified world of international estate planning, shedding light on possible pitfalls and slip-ups. Blunder...more

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

Elena Ruiz and the Cuban Sandwich - The Double Irish with Dutch Sandwich Version for Closely Held Business Owners - Using...

I have been a major fan of Afro-Cuban (Salsa) and Brazilian Bossa Nova music since high school. Most of you know by now that I grew up in the Panama Canal Zone. By the time I got to West Point in the summer of 1978, it was...more

Freeman Law

A Win for Taxpayers—Section 6330(d)(1) is a Nonjurisdictional Deadline

Freeman Law on

Collection Due Process Hearings and Jurisdiction Collection Due Process (“CDP”) hearings are crucial to taxpayers. Taxpayers have a right to a Collection Due Process hearing with the IRS Independent Office of Appeals before...more

Freeman Law

Tax Court in Brief | Cosio v. Commissioner | Collection Due Process and Abuse of Discretion

Freeman Law on

Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No....more

Freeman Law

The Tax Court in Brief - December 2021 #4

Freeman Law on

Ahmed v. Comm’r, T.C. Memo. 2021-142 |December 28, 2021 | Thornton, J. | Dkt. No. 12876-18L - Short Summary. The IRS filed a notice of federal tax lien against Mr. Ahmed with respect to his 2013, 2014, 2015, and 2016...more

Freeman Law

The Tax Court in Brief - December 2021

Freeman Law on

Tax Litigation: The Week of December 6 – December 10, 2021 - Coggin v. Comm’r, 157 T.C. No. 12 | December 8, 2021 | Weiler, J. | Dkt. No. 21580-19 - Short Summary: Alice J. Coggin (“Coggin”), who was married during...more

Williams Mullen

“Sure, You Can Work Remote”...These Words May Have a Huge Cost...

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COVID has not only seen a migration of employees to remote work but has created a new business model that is here to stay. In the midst of COVID, employers were eager to allow their employees to work from home and maintain a...more

Freeman Law

The Tax Court in Brief - August 2021 #5

Freeman Law on

Tax Litigation: The Week of August 23 – August 27, 2021 - Tax Court Case: Estate of Charles P. Morgan, Deceased, Roxanna L. Morgan, Personal Representative and Roxanna L. Morgan v. Comm’r, T.C. Memo 2021-104 | August 23,...more

Proskauer Rose LLP

UK Tax Round Up - August 2021

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In Claims Advisory Group v HMRC, The Upper Tribunal (UT) has confirmed that the service of claiming compensation on behalf of third parties for mis-sold payment protection insurance (PPI), is subject to VAT and not exempt...more

McDermott Will & Schulte

The Rise of Digital Services Taxes

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Governments are starting to catch up with online businesses. Multinational clients that provide online advertising services, sell consumer data, or run online intermediary platforms should prepare themselves for the imminent...more

Foodman CPAs & Advisors

Financial Institutions and Golden Passports

On October 16, 2018, the Organization for Economic Cooperation and Development (OECD) issued guidance to Financial Institutions (FIs) regarding what is known as “Golden Passports”. ...more

Bilzin Sumberg

Retroactive Tax Planning

Bilzin Sumberg on

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

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