Popular, Tax Liability

From Crackdown to Calibration: The UK’s Evolving Carried Interest Regime

Akin Gump Strauss Hauer & Feld LLP on 6/9/2025

In November, we covered the UK government’s proposal to overhaul the tax treatment of carried interest in the United Kingdom—an effort to close perceived loopholes by shifting carried interest fully into the income tax...more

Why Some International Entrepreneurs Use U.S. LLCs Without Paying U.S. Tax

Hone Maxwell on 6/4/2025

In the increasingly global world of online business, it’s not unusual for entrepreneurs, freelancers, and consultants to seek a business structure that supports international operations, offers stable banking options, and...more

Washington State Passes Significant Tax Increases Affecting Both Businesses and Consumers

Ballard Spahr LLP on 5/22/2025

Sweeping legislative changes are reshaping Washington state’s tax landscape. On May 20, 2025, Washington’s governor signed legislation significantly increasing the Business and Occupation (B&O) tax, sales tax, and more,...more

The UK's carbon border adjustment mechanism continues to take shape

A&O Shearman on 5/8/2025

Ahead of the commencement of the UK Carbon Border Adjustment Mechanism (CBAM), key building blocks for its regulatory framework are moving into place. Following consultations in 2023 and 2024, draft legislation and a policy...more

IRS Changes Course on Income Tax Impact of Employee Retention Credit

Ballard Spahr LLP on 4/9/2025

On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

Mayer Brown on 7/18/2024

In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

Rivkin Radler LLP on 4/19/2024

Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

How Bonus Depreciation Can Be A Timely Tool in Real Estate Deals

DarrowEverett LLP on 2/6/2024

So, you’re a real estate investor accustomed to tax mitigation strategies and you are starting to think about your next big project. With that comes so many streams of thought — location, timing, interest rates, partnerships,...more

House Tax Bill Would Greatly Accelerate Employee Retention Credit Filing Deadlines

Ballard Spahr LLP on 1/26/2024

The current draft of the Tax Relief for American Families and Workers Act of 2024 includes a proposed provision that would dramatically accelerate the deadline to file claims for the Employee Retention Credit (ERC) to January...more

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on 8/24/2023

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more

Tax Issues Arising in Connection with Distressed Debt Transactions

Kelley Drye & Warren LLP on 8/8/2023

This client advisory addresses selected federal tax issues arising in connection with distressed debt transactions. Part I of the client advisory addresses tax issues arising at the debt holder (“Holder”) level and Part II,...more

IRS Says Crypto Protocol Changes Are Not Taxable

Cadwalader, Wickersham & Taft LLP on 5/25/2023

On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more

CBDC Pilot Announced; Ethereum Upgrade Completed; U.S. Treasury Department Addresses DeFi Risks; Studies Analyze Crypto Taxation,...

BakerHostetler on 4/17/2023

Montenegro Announces CBDC Pilot, BIS Compares CBDCs to Stablecoins - According to a recent press release, “The Central Bank of Montenegro (CBCG) has agreed to collaborate with the enterprise crypto and blockchain solutions...more

When It Rains, It Pours in Washington State – The Washington Supreme Court Upholds the 2021 Enacted Capital Gains Tax

Foster Garvey PC on 3/27/2023

It is a rainy day in the Pacific Northwest with chances of snow showers. For those taxpayers that reside in the state of Washington or own highly appreciated capital assets located in the state, their day just got a bit...more

Back to the Future ... Cryptocurrency Tax Reporting

Cadwalader, Wickersham & Taft LLP on 1/26/2023

The cryptocurrency industry may be breathing a sigh of relief following the release of recent IRS guidance on cryptocurrency tax reporting, which effectively postpones the January 1, 2023 effective date of the digital asset...more

The Year in Tax Law – 2022 Popular Reads on JD Supra

Beacon Insights by JD Supra on 1/5/2023

A look at some of the most widely read tax-related updates and commentary published on JD Supra during 2022....more

IRS’s Crypto John Doe Summons Expanded While Harper Fights Back

Cadwalader, Wickersham & Taft LLP on 11/29/2022

Since at least 2016 the IRS has been ferreting out taxpayers who failed to report their taxable gains from cryptocurrency transactions by issuing John Doe summonses to crypto exchanges and dealers. A John Doe summons enables...more

Today in Tax: How NFT Sellers Can Prepare for State Taxes

Miller Nash LLP on 9/27/2022

Pennsylvania and Washington became the first two states to offer official guidance on how their existing tax regimes apply to nonfungible token (NFT) transactions. Their approaches offer two blueprints for other states to...more

[Webinar] State of Crypto Market in Argentina and Lessons from the US and Europe - September 21st, 10:00 am - 11:30 am ET

Hogan Lovells on 9/12/2022

Blockchain technology, decentralized finance, and new forms of cryptoassets have a transformational impact on the financial market as we know it. Despite early adoption of cryptocurrencies in Argentina, its central bank is...more

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