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Reporting Requirements Tax Liability Tax Planning

Hone Maxwell

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

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Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Whiteford

Client Alert: Tax Implications of the House v. NCAA Settlement

Whiteford on

The approval of the House v. NCAA settlement marks a watershed moment in college athletics. In addition to $2.8 billion in back damages to former athletes unable to capitalize on the sale of their name, image, and likeness...more

Hone Maxwell

When is a U.S. International Tax Attorney Needed?

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Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more

Hone Maxwell

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

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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

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

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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

Amundsen Davis LLC

No Tax on Tips Act: How Taxpayers Can Prepare

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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

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Cadwalader, Wickersham & Taft LLP

2024 Crypto Tax Year in Review

The crypto tax space saw significant developments in 2024. As 2025 ushers in new regulatory shifts (as our colleagues discussed here), tax changes may be on the horizon. In anticipation, this review revisits crypto tax...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

DLA Piper

Italy - VAT: Italy Broadens Digital Services Tax Scope - Monthly Indirect Tax Alert – January 2025

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Company belonging to Euro 750 Mio Group, will pay DST regardless of their digital service turnover in Italy. ...more

Seyfarth Shaw LLP

IRS Clarifies the Federal Income and Employment Tax Treatment of Contributions to and Benefits Paid from State Paid Family and...

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As mandatory State paid family leave and paid family and medical leave (collectively “PFML”) programs have significantly expanded and proliferated in recent years, participating employers and employees have been faced with a...more

Keating Muething & Klekamp PLL

Sale of QSBS and Installment Sale Reporting

In recent years, the utilization of qualified small business stock (“QSBS”) has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax benefits from Section...more

Littler

IRS Updates Guidance on Section 530 and Worker Status Issues

Littler on

The Internal Revenue Service has released new guidance, Rev. Rul. 2025-3, clarifying the application of Section 530 of the Revenue Act of 1978, Section 3509 of the Internal Revenue Code (IRC), and Section 7436 of the IRC in...more

Jones Day

New Proposed Regulations Address Spin-Off Transactions

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These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more

Morgan Lewis

SEC Disclosure and Taxation of Executive Security Benefits: Legal Requirements and Key Considerations

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Many companies are reevaluating their corporate security practices and considering enhancements to the security protections they provide to their executives and other senior leaders. Companies exploring such security...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Cadwalader, Wickersham & Taft LLP

IRS and Treasury Issue Proposed Regulations on Tax-Free Reorganizations, Spin-Offs

On January 13, the U.S. Treasury and Internal Revenue Service released long-awaited proposed regulations governing the treatment of certain features of tax-free corporate spin-off and split-off transactions.  The IRS and...more

Wilson Sonsini Goodrich & Rosati

Action Required: Share Transfers Pursuant to ISO Exercises and ESPP Purchases

Companies frequently grant incentive stock options (ISOs) or sponsor an employee stock purchase plan (ESPP) to provide tax-advantaged equity incentives to employees that are U.S. taxpayers. One aspect of the tax-advantaged...more

Cooley LLP

Year-End Reporting for ISO Exercises and ESPP Stock Transfers - January 2025

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This alert serves as a reminder of certain year-end reporting requirements imposed under Section 6039 of the Internal Revenue Code of 1986, as amended, with respect to...more

Stinson LLP

1099-K Reporting: More Time to Transition to the $600 Reporting Threshold

Stinson LLP on

In the American Rescue Plan Act of 2021, Congress and the Biden administration lowered the minimum reporting threshold for filing information returns relating to “reportable payment transactions” (a payment card is accepted...more

Cadwalader, Wickersham & Taft LLP

First Stand-Alone Crypto Tax Fraud Case Leads to Guilty Plea

On September 12, 2024, the U.S. Department of Justice (“DOJ”) announced that Frank Richard Ahlgren III pleaded guilty to filing a false tax return underreporting gains from selling $3.7 million in Bitcoin. As we discussed...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: U.S. Tax Reporting for Americans That Live Overseas and Voluntary...

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Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more

McDermott Will & Emery

Weekly IRS Roundup September 23 – September 27, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23, 2024 – September 27, 2024....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

Mayer Brown

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

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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

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