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Tax Code Tax Planning

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part VII – The Rules Relating to the Deductibility of Individual...

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In this seventh installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss provisions of the Act that impact the deductibility of individual charitable gifts under Code Section 170....more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part V – Qualified Small Business Stock Exclusion / Code Section...

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In this fifth installment of my multi-part series on the One Big Beautiful Bill Act, Steve Nofziger and I discuss a provision of the Act that impacts certain business owners who are contemplating a sale of their shares, Code...more

Shumaker, Loop & Kendrick, LLP

The Estate Planner, July/August 2025

Handle an inherited IRA with care - An inherited IRA can be a welcome financial windfall. But the rules governing required minimum distributions (RMDs) from these tax-deferred accounts are complex. IRA recipients should...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part II – Estate and Gift Tax

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In this second installment of our multi-part series on the One Big Beautiful Bill Act (the “Act”), my colleague David Knutson and I discuss the changes made by the Act to the federal estate and gift tax regime....more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

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Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

Proskauer Rose LLP

UK Tax Round Up - January 2025

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Welcome to the January 2025 edition of our UK Tax Round Up. This month has seen a very interesting decision of the Court of Appeal on the significant influence test in the salaried member rules and decisions on the tax...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | February 2025

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Welcome back to the buzz, our monthly cannabis news and policy update. Your at-a-glance source for regulatory developments, agency announcements, and trends impacting the cannabis industry. In this edition of the buzz,...more

Allen Barron, Inc.

How Often to Review Your Trust and Estate Plan

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How often should you review your trust and estate plan? Is there a regular cycle to these reviews, or should they be driven by significant events in your life or the lives of your beneficiaries and executor or trustee? How...more

Bricker Graydon LLP

Do I Need a 409A Valuation for my Company?

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If you have equity as part of your retirement or executive compensation plans, you likely need a 409A valuation. The need for a valuation also applies if you are preparing to issue equity (equity grants or stock options) or...more

Crunched Credit

Time to Fix REMIC:  Grand Bargain Part II

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Last week I talked about the Grand Bargain to fix our business. If we’re fixing to fix our business now, we’ve got to talk REMIC. The Real Estate Mortgage Investment Conduit (REMIC) created as part of the Tax Reform Act of...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Allen Barron, Inc.

Surprising IRS Tax Bracket Changes for 2025

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Have you come across the surprising IRS tax bracket changes for 2025? Yesterday, the IRS released the 2025 income tax brackets for U.S. taxpayers. The inflation adjustments to tax brackets were a pandemic-boosted 7% for...more

Cadwalader, Wickersham & Taft LLP

Recognising “Imported Losses” Under the UK’s Loan Relationship Rules

The United Kingdom (“UK”) has specific corporate tax rules on the taxation of loan relationships (parts 5 and 6 of the Corporation Tax Act 2009 (the “Loan Relationships Regime”)). The Loan Relationships Regime contains rules...more

Seward & Kissel LLP

Final Tax Rules and Transitional Guidance for Broker Reporting

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The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more

Davidoff Hutcher & Citron LLP

Global Wealth, Local Laws: What 8 International Estate Planning Issues Should High-Net-Worth Individuals Consider?

Navigating International Estate Planning - Today, more and more people own property in more than one country, and that requires particular consideration when planning their estate. Traveling has become so easy that many...more

Bowditch & Dewey

Olympic Medals and Income Tax

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The 2024 Paris Olympics are in full swing, and it is never too early for U.S. athletes to consult with their tax advisor. As was done in 2021, the United States Olympic & Paralympic Committee has pledged to award U.S....more

Mayer Brown

Measure ULA Update: Reported Revenue, Applicability to Foreclosures and Legal Challenges

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In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...more

Hogan Lovells

A new form of security in Italy: Non-possessory pledge of moveable goods

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In 2016, Italy introduced a new form of security on moveable goods, which does not require the debtor to surrender the goods to the creditor or a custodian. Instead, it requires the pledgor to register the goods in a digital...more

Carlton Fields

Tax Court Upholds IRS Decision That Premiums Paid to Microcaptive Insurance Companies Did Not Qualify for Tax Deductions

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The U.S. Tax Court recently upheld a determination by the IRS that premium payments to certain microcaptives could not be deducted for tax purposes because the premium payments were not actually for “insurance.”...more

Allen Barron, Inc.

The Sunset of the TCJA – Tax Cuts and Jobs Act of 2017 – Is Scheduled for the End of 2025

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The sunset of the TCJA – the Tax Cuts and Jobs Act of 2017, is currently scheduled for the end of 2025.  The TCJA contributed substantial changes to the US tax code that have benefited many US taxpayers.  How should a US...more

Morgan Lewis

Biden Highlights IRS Plans to Audit Corporate/Partnership Jet Use in State of the Union Address

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In his State of the Union address, President Joseph Biden targeted tax breaks for corporations and wealthy individuals who use private jets as part of a broader goal to make big corporations and the wealthy pay “their fair...more

King & Spalding

France – New Offense of Providing Instruments to Facilitate Tax Fraud

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The fight against tax fraud occupies a central place in the French Finance Act for 2024. Among the various proposals is the new Article 1744 of the French tax code, which creates the offense of making instruments...more

Poyner Spruill LLP

Exploring Estate Tax Deferral

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The passing of a loved one is always a challenging time and navigating the financial implications of administering his or her estate can add yet another layer of complexity to an already emotional experience. Estate Taxes, in...more

McDermott Will & Emery

Advanced Planning Can Reduce Your Tax Burden When Buying Property or Moving to the United States

Moving to or purchasing real estate in the United States as a nonresident requires careful consideration of US federal income, estate and state and local tax laws. Inbound US federal tax planning involves analyzing these laws...more

Freeman Law

Tax Residency Status Modification: Mexican Tax Implication

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For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living. And in an increasingly global...more

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