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Frost Brown Todd

Section 1202 and QSBS: A Survey of States That Don’t Conform to the Federal Treatment

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Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more

Littler

Recent U.S. Tax Court Opinion Illustrates How Language in Settlement Agreements Can Determine Tax Treatment of Payments

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In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more

Ruder Ware

One Big Beautiful Bill Act: Stay Tuned for Our Client Alert Series

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As you may be aware, on July 4, 2025, a landmark piece of tax legislation – commonly referred to as “One Big Beautiful Bill Act” – was signed into law, ushering in some of the most significant changes to the tax code in...more

Eversheds Sutherland (US) LLP

Tax considerations for institutional payments and Fontenot update

As of July 1, 2025, institutions are permitted to make direct payments to student-athletes. Of the many issues raised by institutional payments to student-athletes, tax considerations may not be getting enough attention....more

Blank Rome LLP

Cannabis ESOPs Provide Solutions for Operators

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As we enter Q2 of 2025, the cannabis industry has become increasingly pessimistic about the elimination of Section 280E of the Internal Revenue Code, whether via rescheduling or otherwise. Rescheduling appears unlikely in the...more

Gerald Nowotny - Law Office of Gerald R....

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Seward & Kissel LLP

Section 883 Tax Exemption for Cargo Shipping and Cruise Lines At Risk?

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Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more

Goodwin

Loi de Finances pour 2025

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La Loi de finances pour 2025 (LF 2025) a été publiée au Journal Officiel le 15 février 2025. Le présent bulletin décrit brièvement une sélection de mesures fiscales qu’elle contient....more

Barnea Jaffa Lande & Co.

January 2025: Legislative amendments to real estate taxation in Israel

The new year is already heralding significant tax innovations in Israel in general, and in real estate taxation in particular. Following are highlights of the legislative amendments that were approved by January 2025....more

Foodman CPAs & Advisors

IRS Pilot Mediation Programs

On 1/15/25, the IRS announced three pilot programs to test changes to existing Alternative Dispute Resolution (ADR) programs. The new IRS Pilot Mediation Programs are designed to help taxpayers resolve tax disputes earlier...more

Foodman CPAs & Advisors

Tax Preparation 2025 Useful Pointers

On 12/19/24, anticipating the 2025 filing season, the IRS published Tax Preparation 2025 Useful Pointers in IR-2024-311: Prepare to file in 2025: Get Ready for tax season with key updates, essential tips. As the 2025 filing...more

Rivkin Radler LLP

Will the Federal Estate and Gift Tax Exemption Be Reduced in 2026?

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The federal estate and gift tax exemption changes from year to year. The current combined federal estate and gift tax exemption amount of $13.99 million per person ($27.98 million per married couple) is scheduled to “sunset”...more

Rivkin Radler LLP

Expiring Federal Transfer Tax Benefits – Nothing is Certain or Lasts Forever

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Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more

Foley & Lardner LLP

Tax Court Reaffirms Soroban Holding that “Active” Limited Partners are Subject to Self-Employment Tax

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On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...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

Womble Bond Dickinson

Supreme Court Decision in Connelly v. United States

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On June 6, 2024, the United States Supreme Court issued its decision in in Connelly, As Executor of the Estate of Connelly v. United States, (602 US ________). The decision involves the application of the federal estate tax...more

Freeman Law

Tax Court in Brief | Commonwealth Underwriting & Annuity Servs. v. Comm’r | Denial of Exemption Under IRC 501(c)(15)

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Summary: Commonwealth challenges the IRS’s denial of application for tax exemption under 501(a), claiming, by submission for declaratory judgment, to be an organization described in section 501(c)(15). Commonwealth was...more

Freeman Law

Tax Court in Brief | Furrer v. Comm'r | Charitable Remainder Trusts; Non-Cash Charitable Contribution Substantiation; Taxability...

Freeman Law on

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

Cadwalader, Wickersham & Taft LLP

UK Government Considers Changes to the Rules on Sovereign Immunity from Direct Taxation

The UK Government has recently consulted on a revised approach to sovereign immunity from direct taxation. The consultation was brought about owing to the view that whilst the scope of sovereign immunity-based exemptions has...more

Freeman Law

Church Status: Can (and should) your religious nonprofit seek church status with the IRS?

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Can and should your religious organization seek church status with the IRS? A look at a few pros, cons, and due diligence considerations....more

Freeman Law

Tax Court in Brief | Hicks v. Commissioner: Dependency Deductions

Freeman Law on

Tax Litigation: The Week of February 21, 2022, through February 25, 2022 Hoops, LP v. Comm’r, T.C. Memo. 2022-9 | February 23, 2022 | Nega, J. | Dkt. No. 11308-18 Hicks v. Comm’r, T.C. Memo. 2022-10 | February 23,...more

Freeman Law

Tax Court in Brief – Ola-Buraimo v. Comm’r

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The Tax Court in Brief February 14 – February 18, 2022 - Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

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...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

McDermott Will & Schulte

Weekly IRS Roundup September 27 – October 1, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

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In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more

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