News & Analysis as of

Tax Cuts and Jobs Act Tax Code Internal Revenue Service

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part III – Gambling / Code Section 165(d)

Foster Garvey PC on

In this third installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss a provision of the Act that may not impact a large segment of the population, but which is interesting and worthy 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

Allen Barron, Inc. on

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

Roetzel & Andress

Now That We’ve Seen the Eclipse, It’s Time To Plan for the TCJA Sunset

Roetzel & Andress on

As the ball drops in Times Square on December 31, 2024, many of the tax breaks established by the Tax Cuts and Jobs Act (TCJA) of 2017 will disappear. While the TCJA made some permanent tax cuts, a number of tax cuts and...more

Allen Barron, Inc.

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

Allen Barron, Inc. on

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

Morgan Lewis on

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

ArentFox Schiff

Five, Six, Seven, Eight, Nine, Ten . . . Will We Love 2024? Top 10 Tax Issues for the Year

ArentFox Schiff on

The 2024 election year promises to make taxes front-of-mind for many business and individual taxpayers. Beyond the election, there are other note-worthy developments, along with several highly anticipated tax law cases that...more

McDermott Will & Schulte

Kansas Decouples from GILTI and 163j

Yesterday afternoon the Kansas legislature overrode Governor Laura Kelly’s veto of Senate Bill (SB) 50, effectively enacting the provisions of the bill into law. Among those are provisions decoupling from certain Tax Cuts and...more

Rivkin Radler LLP

If You Sell Marijuana In Any Form, Uncle Sam Wants His Cut

Rivkin Radler LLP on

More and more states across the country are legalizing the sale of marijuana products for medical and/or recreational purposes, but marijuana remains effectively prohibited under federal law as a Schedule I controlled...more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

Seyfarth Shaw LLP on

Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

Farrell Fritz, P.C.

Responding To The Democratic Party’s Tax Plans

Farrell Fritz, P.C. on

The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

McDermott Will & Schulte

Weekly IRS Roundup August 10 – August 14, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 10, 2020 – August 14, 2020... August 10, 2020: The IRS published corrections to a notice...more

McDermott Will & Schulte

Weekly IRS Roundup July 27 – July 31, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 27, 2020 – July 31, 2020... July 28, 2020: The IRS issued final regulations providing...more

Bracewell LLP

Straight from the Source: Proposed Regulations Seek to Implement TCJA Changes to Source of Income Rules, Altering Treatment for...

Bracewell LLP on

The source of income is a critical component of U.S. tax rules for both U.S. taxpayers operating internationally (namely, with respect to foreign tax credit planning) and foreign persons with investment or other activity in...more

Roetzel & Andress

Personal Goodwill And Loss Limitations Under §461(L) Of The Tax Code Are Likely To Be Tested In Future Tax Appeals And Must Be...

Roetzel & Andress on

An important tax code update that business owners in Ohio and across the country should take note of is part of the recent tax reforms concerning personal goodwill and its tax treatment in recent and future business...more

McDermott Will & Schulte

Weekly IRS Roundup January 14 – 18, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 14 – 18, 2019. January 15, 2019: The IRS issued final regulations implementing the...more

Bowditch & Dewey

Tax Cuts and Jobs Act: Impact on Mortgage Interest Deductions

Bowditch & Dewey on

The Tax Cuts and Jobs Act of 2017 (“TCJA”) made substantial changes to the Tax Code of 1986 by reducing tax rates and “simplifying” tax compliance for many by significantly increasing the standard deduction and eliminating...more

Brooks Pierce

Investing In Qualified Opportunity Funds

Brooks Pierce on

The Tax Cuts and Jobs Act signed on Dec. 22, 2017, amended the tax code to encourage economic growth and investment in designated distressed communities, called qualified opportunity zones, by providing federal income tax...more

Holland & Knight LLP

Tax Changes Impacting Government Enforcement: Comments Due November 13, 2018

Holland & Knight LLP on

As described in a blog post on March 13, 2018, Section 13306 Tax Cuts and Jobs Act, P.L. 115-97 (Dec. 22, 2017) revises the longstanding rule on the deductibility as a business expense (or lack thereof) of "any fine or...more

Holland & Knight LLP

Opportunity Zone Investments: What You Need to Know and Potential Scenarios - A New Opportunity for Investors to Defer Taxable...

Holland & Knight LLP on

• The Internal Revenue Service (IRS) on Oct. 19, 2018, issued much anticipated proposed regulations (the Proposed Regulations) and other guidance on tax benefits arising from investments in "qualified opportunity zones" that...more

Verrill

New Tax Credit for Paid Leave – Part 2: IRS Issues Helpful Guidance

Verrill on

As expected, the IRS recently issued additional guidance concerning the new paid leave tax credit codified as Code Section 45S. The guidance, set forth in IRS Notice 2018-17, is presented in the form of 34 questions and...more

Akin Gump Strauss Hauer & Feld LLP

Opportunity Zones: How Communities Can Leverage This New Provision to Jumpstart Investment

• Even though practitioners are awaiting proposed regulations on the new opportunity zone provision, interested parties are already starting to set up qualified opportunity funds to pool investor capital. • States, cities,...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Bricker Graydon LLP

New guidance on the Tax Cuts and Job Act’s unrelated business taxable income changes

Bricker Graydon LLP on

Recently, the Internal Revenue Service (IRS) released Notice 2018-67 to provide interim guidance to exempt organizations in calculating unrelated business taxable income (UBI)....more

Fenwick & West LLP

US Taxation of IP After Tax Reform

Fenwick & West LLP on

Introduction - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out the details of how...more

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