President Trump’s sweeping package of domestic legislation, H.R. 1 (originally titled the One Big Beautiful Bill Act (the “OBBB”)), became law on July 4, 2025. In addition to dramatically reshaping the landscape for...more
On June 16, 2025, the Senate Finance Committee released a draft package that includes a major provision aimed at curbing the use of state pass-through entity taxes (PTETs) to bypass the federal $10,000 cap on state and local...more
The Senate Finance Committee recently released its own draft of the “One Big Beautiful Bill Act” (the Bill) previously passed by the House as H.R. 1. Both the House and Senate versions of the Bill impose restrictions on...more
When toddlers engage in parallel play, the children play adjacent to each other, but do not try to influence one another’s behavior. Apparently, parallel play can extend well into adulthood and to the writing of federal...more
On February 21, 2024, Senate Finance Committee Chairman Ron Wyden released a report on the findings from a self-styled “democratic staff investigation” into the use of private placement life insurance (PPLI) by...more
It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more
One of the more significant issues that taxpayers and tax practitioners have faced in recent months is the Tax Cuts and Jobs Act’s (TCJA) amendment to Section 174, requiring capitalization of previously deductible R&D and...more
Debt Limit Negotiations Stall as Treasury Department Begins Extraordinary Measures. On Jan. 19, the U.S. government reached its $31.4 trillion borrowing limit, which was signed into law by President Joe Biden late last year....more
LEGISLATIVE LOWDOWN - Congress Advances Towards CR as Deadline Approaches. Yesterday, Senate Democrats proposed legislation to fund the federal government through Dec. 16 with the use of a continuing resolution (CR). The...more
Treasury Secretary Janet Yellen testified before the Senate Finance Committee and the House Ways and Means Committee this week to discuss the Biden administration's fiscal year 2023 budget proposal for the Treasury...more
Bajo el concepto de “FATCA recíproca”, las instituciones financieras y los corredores deben comenzar a prepararse para asumir mayores y más amplias responsabilidades de reportaje. Como partes interesadas de FATCA, las...more
Congressional Tax Staffers Outline Agenda. Several senior staffers on the House Ways and Means Committee and the Senate Finance Committee—Andrew Grossman, Courtney Connell, Derek Theurer and Tiffany Smith—participated in a...more
The House and Senate will reconvene Tuesday at 2:00 p.m. and Monday at 3:00 p.m., respectively....more
Under the concept of “Reciprocal FATCA” financial institutions and brokers ought to start preparing to assume greater and expanded reporting responsibilities. As FATCA Stakeholders, financial institutions, and brokers, such...more
The military conflict between Russia and Ukraine remains front of mind for Congress. Shortly after hearing from Ukrainian President Volodymyr Zelenskyy last week, the House passed with broad bipartisan support a bill that...more
On Thursday, Feb. 17, the Senate Finance Committee held a hearing entitled “Spotlighting IRS Customer Service Challenges.” The witnesses included National Taxpayer Advocate Erin Collins with the Internal Revenue Service...more
On April 5, Senate Finance Committee Chair Ron Wyden (D-OR), as well as Sens. Sherrod Brown (D-OH) and Mark Warner (D-VA), offered an international tax framework as a starting point to discussions on revamping the current...more
It has been more than eight months since the enactment of the CARES Act, yet here we are, with the end of 2020 in sight, and we are still debating whether taxpayers should be allowed to claim a deduction for business expenses...more
In IRS Notice 2020-32 issued on April 30, 2020, the IRS has clarified that no deduction is allowed for expenses paid with funds loaned to a business through the CARES Act’s Paycheck Protection Program if payment of the...more
Welcome to 2020! Although we have enjoyed the time off, we have been itching to get back into the swing of things. Since you have not seen Taxation & Representation in your inbox since the previous decade, we thought it was...more
TAX TIDBIT - Five Takeaways and a Falsehood: Test Your Knowledge of the Ways and Means Tax Markup - On Thursday, the House Ways and Means Committee marked up and approved the following four bills, largely along...more
In This Issue: - Tax Tidbit - Legislative Lowdown - RegWatch - 1111 Constitution Avenue - At a Glance - Brownstein Bookshelf - Regulation Station ...more
Tax Tidbit - Regulators have until June 22 to finalize guidance on the Tax Cuts and Jobs Act (P.L.115-97). The 18-month mark since the legislation was signed into law is quickly approaching. The Treasury Department and...more
In This Issue - - Tax Tidbit - Legislative Lowdown - RegWatch - 1111 Constitution Avenue - 2020 Vision - At a Glance - Brownstein Bookshelf...more
TAX TIDBIT - SPOILER ALERT: The following piece contains Game of Thrones and Avengers Endgame spoilers—nothing that you probably would not have guessed on your own. But, we would rather not be responsible for ruining a...more