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Schwabe, Williamson & Wyatt PC

U.S. Treasury Announces Tribal Consultation on General Welfare Exclusion Act

On June 30, 2025, the United States Department of the Treasury announced that it will be holding an online tribal consultation with Alaska Native Corporations on July 29, 2025, from 1:30 pm to 4:30 pm ET, to discuss the...more

Proskauer - Tax Talks

California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules

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On May 20, 2025, California’s Franchise Tax Board (“FTB”) released changes to the proposed regulations (“Draft Regulations”) that would amend the rules regarding market-based sourcing for sales other than sales of tangible...more

Alston & Bird

Asset Managers with California Investors Could Face New State and Local Taxes

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Our State & Local Tax Team breaks down proposals from both California and San Francisco that would use investors’ location to decide whether to tax out-of-state asset managers....more

Fox Rothschild LLP

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales

Fox Rothschild LLP on

An installment sale occurs when property is disposed of and at least one payment is received after the tax year of the disposition. See I.R.C. § 453. Under a standard installment sale, the buyer makes scheduled payments to...more

Fenwick & West LLP

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

Fenwick & West LLP on

The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

Burr & Forman

Are Overtime Wages and Tips Exempt From Income Tax? What Employers Need to Know to Prepare

Burr & Forman on

Join Carlton Hilson and Amy Jordan Wilkes as they discuss the recent proposals that aim to eliminate federal taxes on overtime pay and tips and what this means for employers....more

Husch Blackwell LLP

New Jersey Proposes Rules Incorporating Parts of MTC's Public Law 86-272 Guidelines

Husch Blackwell LLP on

Public Law 86-272 (P.L. 86-272) was first adopted by the U.S. Congress in 1959 to address the business concerns of tax implications from traveling salesmen working in multiple states. To address these concerns, Congress used...more

Fenwick & West LLP

U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications

Fenwick & West LLP on

The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more

Eversheds Sutherland (US) LLP

California’s proposed market sourcing reg raises questions

The California Franchise Tax Board (FTB) has proposed amendments to its regulations that govern how sales of services and intangibles are sourced for income tax purposes. The changes to this income tax apportionment...more

Freeman Law

Treasury Issues Final Digital Asset Sourcing Regs and Proposed Cloud Transaction Sourcing Regs

Freeman Law on

On January 14, 2025, the Treasury Department and IRS issued final and proposed regulations on sourcing income from digital content and cloud transactions. Why is Source Important? While U.S. persons generally are...more

McDermott Will & Schulte

IRS Roundup January 6 – 10, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6, 2025 – January 10, 2025....more

Wilson Sonsini Goodrich & Rosati

IRS Issues Final Digital Content and Cloud Transaction Regulations

On January 10, 2025, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations (the Final Regulations) regarding the classification of digital content transactions and cloud...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Proposed 162(m) Regulations Defining the Scope of Expanded Covered Employees

On January 16, 2025, the IRS and the Department of the Treasury published proposed regulations relating to Section 162(m) of the Internal Revenue Code. The proposed regulations provide guidance on, and implement, the...more

Walkers

Channel Islands Regulatory Update - January 2025

Walkers on

On 5 December 2024 the UK's Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 came into force. The UK Regulations are made under the UK Sanctions and Anti-Money Laundering Act 2018 ("SAMLA") and make...more

Eversheds Sutherland (US) LLP

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

Cadwalader, Wickersham & Taft LLP

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.  By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

Groom Law Group, Chartered

Proposed Rule Has Serious Implications on the Taxation of Fixed Indemnity and Other Similar Coverages

On July 7, the Departments of Labor, Treasury, and Health and Human Services published a proposed rule (“Proposed Rule”) regarding, among other things, the requirements for fixed and hospital indemnity insurance to be...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the Taxation of Partnerships

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On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

Freeman Law

Texas Tax Roundup | February 2022 (RECOVERED!)

Freeman Law on

Howdy y’all!  Has it been a month already?  We’ve got another action-packed month of Comptroller-related news.  Here we go! Court Cases Courts of Appeals Hegar v. Black, Mann, and Graham, L.L.P., No. 03-20-00391-CV (Tex....more

Bradley Arant Boult Cummings LLP

ADOR Issues Helpful Estimated Tax Guidance on New Elective PTE Tax

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called “SALT Cap” enacted as part of the Tax Cuts and Jobs Act of 2017 that limits the deductibility of...more

Goodwin

OCC Grants National Trust Bank Charter to Third Cryptocurrency Firm

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval to a third cryptocurrency firm chartering a national trust bank; the Consumer Financial Protection Bureau (CFPB)...more

McDermott Will & Schulte

Six Takeaways: Utilization and Structuring For Section 45Q Carbon Capture Credits

The Treasury Department and IRS recently published proposed regulations implementing the Section 45Q carbon capture and sequestration credit. The regulations clarify some questions about the credit, though many questions...more

McDermott Will & Schulte

[Webinar] Utilization and Structuring For Section 45Q Carbon Capture Credits - June 11th, 12:30 pm EST

The Internal Revenue Service (IRS) has released a long-awaited proposed rule to implement section 45Q of the Internal Revenue Code, the statutory provision that creates a tax credit for capturing and sequestering carbon...more

Snell & Wilmer

What’s in the Cloud? Proposed IRS Rules for Digital and Cloud Transactions

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The long wait is over – the Internal Revenue Service (IRS) has finally issued proposed regulations (the Cloud Regulations) addressing the tax treatment of cloud transactions. Until now, there was no guidance specifically...more

White & Case LLP

Luxembourg pre-2015 tax rulings: the end is nigh

White & Case LLP on

On 14 October 2019, the Luxembourg Government submitted to the parliament a draft bill of law for the 2020 budget (the Budget 2020 Bill of Law), which includes a new provision that, if adopted, could have significant...more

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