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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

Blank Rome LLP

One Big Beautiful Bill Act: Key Business, International, and Employment Tax Provisions

Blank Rome LLP on

The federal government enacted the One Big Beautiful Bill Act (the “Act”) on July 4, 2025. The Act extends and makes permanent certain tax provisions introduced in the Tax Cuts and Jobs Act (the “TCJA”) that were scheduled to...more

McCarter & English, LLP

One Big Beautiful Bill Act Tax Law Updates–Private Educational Institutions and Nonprofits

On July 4, 2025, President Trump signed into law legislation commonly referred to as the “One Big Beautiful Bill Act” (OBBBA), which includes provisions that specifically affect private primary, secondary, and post-secondary...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

Foley & Lardner LLP

One Big Beautiful Bill Updates to Qualified Small Business Stock Rules under Section 1202

Foley & Lardner LLP on

As part of the newly enacted One Big Beautiful Bill Act (the OBBBA),[1] Congress adopted the first substantive amendments to Section 1202[2]–which prescribes the qualified small business stock (QSBS) rules–in over a decade...more

Mintz - Tax Viewpoints

Senate Finance Committee’s Take on the One Big Beautiful Bill Act

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Following our prior alert on the House Ways & Means Committee version of the One Big Beautiful Bill Act (“OBBBA”), the House passed its version of the OBBBA (“House Bill”) on May 22, 2025, and on June 17, 2025 the Senate...more

Orrick, Herrington & Sutcliffe LLP

Senate Bill Unexpectedly Proposes Significant Expansion of QSBS Benefits

On June 16, 2025, the Senate Finance Committee introduced a bill that would significantly expand the benefits available for qualified small business stock (QSBS). The expanded QSBS benefits apply to stock acquired after the...more

Whiteford

Client Alert: Inside the One Big Beautiful Bill Crucial Tax Updates for Individuals, Business Owners, and Nonprofits

Whiteford on

On May 22, 2025, the House of Representatives passed H.R. 1-119th Congress (2025-2026), titled as the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses soon to sunset provisions of...more

Allen Barron, Inc.

Tax Developments for US Expatriates

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There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more

Eversheds Sutherland (US) LLP

San Francisco’s proposed regulation imitates California’s proposed regulation

In November 2024, voters approved Proposition M which provided for an overhaul of San Francisco’s gross receipts tax. Proposition M changed the allocation and apportionment rules for most industries, generally requiring that...more

Mayer Brown

STF Establishes Non-Incidence of ISS on Commissioned Manufacturing Activities

Mayer Brown on

The Brazilian Supreme Court (STF) decided that the Tax on Services’ (ISS) non-levy on toll commissioned manufacturing activities, whenever these activities refer to the intermediary activities of a production cycle. The...more

McCarter & English, LLP

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

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

Miller Canfield

Comments Solicited on Michigan Research Credit Draft Notice

Miller Canfield on

The Michigan Department of Treasury released a draft of a notice regarding the new research and development credit. ...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 3, 2025

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

Stikeman Elliott LLP

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

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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

Dorsey & Whitney LLP

Certain Canadian Corporations May Unknowingly be Subject to U.S. Federal Backup Withholding and Reporting Requirements With...

Dorsey & Whitney LLP on

Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more

McDermott Will & Schulte

Weekly IRS Roundup November 13 – November 17, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 13, 2023 – November 17, 2023. ...more

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