Impuesto de Timbre: Cuantía indeterminada
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
Exploring Carried Interest in Upper Tier Private Equity Structures — PE Pathways
Insider Transaction Traps for the Unwary
Essentials for Balancing Taxes and Legal Risk
Business Better Podcast Episode: Bridging Campuses: Legal Insights on Education Industry Consolidation - Real Estate and Tax
Maximizing Financial Growth: Insights on HSAs and Smart Investment Strategies with Shaun Eddy
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
5 Key Takeaways | Income Tax Jeopardy! A Potpourri of Hot Topics
REFRESH: Loot and Private Foundation Rules – Part 2
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Candidate Campaign Intervention
Domestic Tax Planning - Podcast with Janathan Allen
Tax Liability Insurance Products: A Hidden Gem in the Transactional Lawyer’s Tool Box
JONES DAY PRESENTS®: Tax Implications of Telehealth as Remote Services Become Norm
Podcast: Got Mail? What to Do When the IRS Contacts You [More with McGlinchey, Ep. 42]
At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more
What is tax-loss harvesting? “Tax-loss harvesting,” in its simplest form, is the sale of a capital asset at a loss to “mop up” tax that would otherwise be due on capital gain from the sale of another capital asset. Capital...more
On July 1, 2025, a little over two weeks after the Senate Finance Committee released its draft tax title (the “Initial Senate Draft”), the U.S. Senate secured sufficient votes to advance its version of the “One Big Beautiful...more
The US Senate released a draft tax bill (Senate Tax Bill) on June 16, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management community, with a focus on how the Senate Tax Bill...more
On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”). While the Senate...more
On May 22, 2025, the House of Representatives passed a tax bill (House Tax Bill) that proposes to make permanent – and increase – the section 199A deduction for ordinary REIT dividends to 23 percent. This change would reduce...more
If enacted, the House Committee on Ways and Means’ tax bill, entitled “The One, Big, Beautiful Bill,” could affect certain institutional investors. Among other measures, the proposed legislation would impose elevated US tax...more
Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more
As investors increasingly leverage Section 1031 exchanges to defer capital gains taxes, nuanced scenarios involving interest income on exchange proceeds require careful analysis. A critical but often overlooked aspect arises...more
On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more
On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...more
On May 22, 2025, the House of Representatives passed a tax bill with some limited amendments (House Tax Bill). The House Tax Bill will now head to the Senate, where additional amendments could be made. Below, we outline five...more
A 1031 UPREIT (Umbrella Partnership Real Estate Investment Trust) transaction allows real estate investors to exchange property on a tax-deferred basis under IRS Section 1031 while gaining diversification and liquidity by...more
On May 12, 2025, the House Committee on Ways and Means Chairman Jason Smith (R-MO) released an amended 389-page bill, entitled “The One, Big, Beautiful Bill,” and the staff of the Joint Committee on Taxation released a...more
Expanding into the U.S. is a major milestone for many foreign companies. With its large consumer base, strong legal protections, and global influence, the United States remains one of the most attractive markets in the world....more
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
U.S. start-up investors are increasingly looking overseas for investment opportunities. As U.S. investment in UK and other non-U.S. start-ups rises, founders of those start-ups should be aware of the potential impact of the...more
Internal Revenue Code (IRC) Section 1202 offers a significant tax incentive for investors in qualified small business stock (QSBS). This provision allows eligible shareholders to exclude up to 100% of capital gains realized...more
Founders, entrepreneurs, venture capitalists and other investors (all of which are collectively referred to herein as “investors”) should be familiar with Internal Revenue Code Section 1202, a valuable provision that...more
Stamp Duty Land Tax Changes from April 2025: What Buyers Need to Know - From 1st April 2025, significant changes to Stamp Duty Land Tax (SDLT) will take effect, impacting buyers across England and Wales. These adjustments...more
Growing companies will often use acquihires to bring in a team of new employees. This can be more efficient and effective than hiring one by one, especially if the team being brought aboard works well together and has...more
Orrick's UK Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of...more
Continued pressures created by elevated levels of mortgage interest rates, vacancies, as well as stricter lending policies, point to higher capitalization rates, lower property values and tax appeal opportunities in 2025....more
A few weeks ago, someone at a holiday party asked “Whitt, why doesn’t Budding Trends take on the weighty legal issues of the day and instead resort to cheap pop culture references and puns?” I thought about responding with a...more
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