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Foley & Lardner LLP

One Big Beautiful Bill Updates to Qualified Small Business Stock Rules under Section 1202

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As part of the newly enacted One Big Beautiful Bill Act (the OBBBA),[1] Congress adopted the first substantive amendments to Section 1202[2]–which prescribes the qualified small business stock (QSBS) rules–in over a decade...more

Seyfarth Shaw LLP

7 Key Changes to the Qualified Opportunity Zone Incentive Under the One Big Beautiful Bill Act

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On July 4, President Trump signed into law H.R. 1, the One Big Beautiful Bill Act (OBBBA), a sweeping 870-page piece of legislation that introduces significant changes across various areas of federal policy. While full...more

McDermott Will & Emery

The Proposed US Tax Regime for Non-US Investors and Companies

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On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Goodwin

Pillar II in Luxembourg: What Investment Funds Need to Know

Goodwin on

The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more

Morgan Lewis

Treasury and IRS Promulgate Final Regulations Governing Resolution of Federal Tax Controversies by the Independent Office of...

Morgan Lewis on

The US Department of the Treasury and the Internal Revenue Service (IRS) have released Final Regulations related to the resolution of federal tax controversies by the Independent Office of Appeals (Appeals), largely rejecting...more

Williams Mullen

[Event] 2025 Winter Tax Forum - February 6th, Richmond, VA

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Join Williams Mullen for our hybrid 2025 Winter Tax Forum on Thursday, February 6th. Our speakers, Anna Derewenda, Kyle Wingfield, Kevin Bender, and Patrick Carr will provide an update on the following: - New Basis...more

Husch Blackwell LLP

Time to Restate? It's Not Too Late! Upcoming Restatement Deadlines for Pre-Approved Retirement Plans

Husch Blackwell LLP on

The Internal Revenue Service (IRS) regularly requires retirement plans to incorporate new laws and regulations. To ensure that pre-approved retirement plans incorporate these required legal and regulatory updates, the IRS...more

McDermott Will & Emery

Weekly IRS Roundup December 30, 2024 – January 3, 2025

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 30, 2024 – January 3, 2025. December 30, 2024: The IRS released Internal Revenue Bulletin 2025-1,...more

Cadwalader, Wickersham & Taft LLP

Finally Final Crypto Reporting Regulations

On June 28, 2024, the Treasury and the IRS released final regulations on reporting requirements for brokers of digital assets (the “Final Regulations”) and provided transitional relief, including Notice 2024-56, Notice...more

Littler

Watch Out New York – New Jersey Wants Its Taxes Too!

Littler on

On July 21, 2023, New Jersey Governor Phil Murphy signed Assembly Bill No. S3128/A4694 into law, which implements an aggressive tax treatment of nonresidents who work for New Jersey employers.  The law essentially adopts the...more

Cadwalader, Wickersham & Taft LLP

Treasury Holds Fast on Centralized Partnership Audits

On December 8, Treasury issued final regulations (the “Final Regulations”) updating the existing centralized partnership audit regime. These regulations largely adopt the provisions of regulations that were previously...more

Goulston & Storrs PC

Taxachusetts Redux? The New Massachusetts Millionaires Tax

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On November 8, 2022, Massachusetts voters elected to adopt Question 1, the so-called Fair Share Amendment or Massachusetts Millionaires Tax, through a ballot referendum. The referendum amends the Massachusetts state...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Regulation: Statutes, Pillars, and the Build Back Better Act

In the new episode of our tax podcast, “GILTI Conscience,” partners Nate Carden and David Farhat speak with Skadden of counsel Paul Oosterhuis and associate Huzefa Mun about tax legislation, including how the potential...more

McDermott Will & Emery

[Webinar] Tax in the City® - March 1st, 11:30 am - 1:00 pm PDT

The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies. Join us for our first Tax in the City® program of 2022, which will cover federal and...more

McDermott Will & Emery

[Webinar] 2020 Family Office Tax Roundtable - October 21st, 11:00 am - 2:00 pm PDT

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McDermott Will & Emery’s Family Office Tax Roundtable provides participants with an interactive virtual program focused on select income and transfer tax considerations for family enterprises. Attendees will hear...more

Vinson & Elkins LLP

[Webinar] All in the Family: Applying the Business Interest Expense Limitation Within Groups - September 30th, 12:00 pm - 1:00 pm...

Vinson & Elkins LLP on

The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Polsinelli

Polsinelli Commentary on the Final Opportunity Zone Regulations

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Treasury issued final Opportunity Zone Regulations on December 19, 2019 (“Final Regulations”).  These Final Regulations update the first two rounds of Proposed Regulations (issued on October 29, 2018 and April 17, 2019)....more

Herbert Smith Freehills Kramer

New Treasury Regulations and IRS Notice Regarding Withholding on Dividend Equivalent Payments to Foreign Holders

On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Partridge Snow & Hahn LLP

Final Opportunity Zone Treasury Regulations Released

On Thursday, December 19th, the U.S. Department of Treasury released the long-awaited final Opportunity Zone Treasury Regulations (the “Final Regulations”). The Final Regulations and explanatory materials that span 544 pages,...more

Genova Burns LLC

Estate Tax "Clawback" Relief Announced; But of Limited Application

Genova Burns LLC on

For those of sufficient wealth to be concerned about federal estate taxes, lifetime gift giving can be an effective strategy. Although the estate tax is imposed on the aggregate of the taxable estate and lifetime taxable...more

McDermott Will & Emery

Weekly IRS Roundup December 2 – 6, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 2 – 6, 2019. December 2, 2019: The IRS issued final regulations providing guidance...more

McDermott Will & Emery

Weekly IRS Roundup November 18 – 22, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18 – 22, 2019. November 19, 2019: The IRS published final regulations that affect United...more

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