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Hone Maxwell

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

Hone Maxwell on

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

Mayer Brown

Brazilian Internal Revenue Service Publishes New Rules for Low-Value Debts and Debts Up to BRL 50 Million

Mayer Brown on

On July 7, 2025, the Brazilian Internal Revenue Service (IRS) published Notices No. 4/2025 and No. 5/2025, introducing new modalities of tax settlement by adhesion within the scope of administrative tax litigation, with...more

BakerHostetler

[Podcast] An Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more

Hanson Bridgett

Timing is Everything for QSBS After the One Big Beautiful Bill Act

Hanson Bridgett on

The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, establishes new phased-in benefits for Qualified Small Business Stock (QSBS) held for at least three years. ...more

McDermott Will & Schulte

IRS roundup: June 3 – 17, 2025

McDermott Will & Schulte on

June 16, 2025: Billy Long was sworn in as the 51st IRS Commissioner after having been confirmed by the US Senate on June 12. Long served as a US Representative for Missouri’s 7th congressional district from 2011 to 2023. His...more

McCarter & English, LLP

Proposed Corporation Business Tax Regulations, Proposing Sweeping Changes, Published in ‘New Jersey Register’

McCarter & English, LLP on

On February 18, the New Jersey Division of Taxation published proposed corporation business tax (CBT) regulations that incorporate changes associated with 2023 reform legislation, as well as additional changes intended to...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 3, 2025

Eversheds Sutherland (US) LLP on

Tax developments - The validity of the 245A DRD for indirectly owned foreign corporations - On January 21, 2025, the IRS filed a motion for summary judgment asking the Tax Court to hold that Sysco Corporation (Sysco)...more

Husch Blackwell LLP

New Mexico Rules That Anesthesia Services Can Be Purchased Exempt for Resale

Husch Blackwell LLP on

New Mexico’s gross receipts tax (what the state calls its sales tax) is generally imposed on receipts derived by the seller from performing services in the state; however, a resale of the services is not generally taxable if...more

Stikeman Elliott LLP

Tax Court of Canada Denies GST/HST Input Tax Credit Claims in Connection with a Settlement Payment

Stikeman Elliott LLP on

In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...more

Bradley Arant Boult Cummings LLP

Blazing Trails: Exploring ESOPs in the Cannabis Industry

Bradley Arant Boult Cummings LLP on

The budding cannabis industry, despite its rapid growth and gradual acceptance in recent years, still faces a major sustainability challenge: Cannabis businesses cannot deduct most ordinary business expenses. Under Internal...more

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