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]
The Brazilian Attorney General's Office of the National Treasury (PGFN) has published PGDAU Notice No. 11/2025 (the “Notice”), which sets forth the conditions for tax settlements to regularize debts up to BRL 45 million...more
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
On June 17, 2025, the Internal Revenue Service ("IRS") announced improvements to its Pre-Filing Agreement ("PFA") program. The IRS press release is available here. The PFA program allows Large Business & International...more
Seven years after relevant judgments from the CJEU, the Belgian VAT authorities now (broadly) allow the recovery of input VAT beyond the standard Belgian limitation period of three years, subject however to strict conditions....more
Starting from January 2025, staff secondments are subject to VAT even where limited to the mere reimbursement of costs, provided that the relevant payment received qualifies as consideration for a supply of services. This...more
On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more
On 26 May 2025, the UAE Federal Tax Authority (FTA) issued Public Clarification VATP044, confirming that UAE-based recipients of Concerned Services are not required to self-issue tax invoices if they retain valid invoices or...more
The current US administration has added tariffs to a variety of goods sold by US retailers but imported from foreign sellers. In other cases, foreign retailers subject to tariffs, may sell their products directly to US...more
Employers that do not timely deposit participant deferrals and loan contributions to their employer sponsored retirement plans can be subject to Department of Labor (DOL) penalties for breaching their fiduciary duties....more
This client alert discusses recent developments relevant to members of UK LLPs in respect of the UK’s salaried member employment tax rules. In particular, it focuses on recent developments in relation to Condition B (the...more
The Michigan Department of Treasury recently issued updated guidance addressing successor liability in response to Mertz v. Dep’t of Treasury [Dkt. No. 365480 (June 13, 2024)], a recent case before the Michigan Court of...more
El Servicio de Impuestos Internos (SII) dictó la Circular N°23 que imparte instrucciones sobre el nuevo texto del artículo 64 del Código Tributario. A modo de contexto, el SII tiene una facultad legal para tasar el precio o...more
Chile’s Internal Revenue Service (SII) has issued Circular No. 23, providing instructions on the new text of Article 64 of the Tax Code – also known as the Tax Reform. In Chile, the SII has the legal power to assess the...more
The IRS recently released new FAQ guidance providing a simplified procedure for addressing income tax amendments and refund claims related to Employee Retention Credit (ERC) determinations. See IRS FAQs. Taxpayers claiming...more
On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS - The previous IRS...more
On June 30, 2023, the United States Department of the Treasury (“Treasury”) published Final Regulations as guidance on the transition from the use of the Interbank Offer Rate (IBOR) to the Secured Overnight Financing Rate...more
On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more
Electric vehicle and electric battery manufacturers and critical mineral producers will want to take note of a notice of proposed rulemaking (NPRM) on Section 30D of the Internal Revenue Code of 1986, as amended, released by...more
On March 17, 2023, the IRS Exempt Organizations and Government Entities Division published two Technical Guides: (1) TG 1 Instrumentalities of the United States, Government Corporations, and Federal Credit Unions; and (2) TG...more
At the end of 2022, the Department of the Treasury and the Internal Revenue Service (together, the “IRS”) issued two sets of guidance – a final rule and a proposed rule – addressing the application of certain provisions of...more
IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition - Introduction - The IRS recently released two chief counsel...more
As noted in yesterday’s post, the IRS published Notice 2022-61 regarding the prevailing wage & apprenticeship requirements. In addition, the Department of Labor yesterday issued two Frequently Asked Question (FAQ) documents:...more
The Internal Revenue Service (IRS) was one of the first United States regulators to provide guidance on the tax treatment of virtual currencies such as Bitcoin. Starting back in 2014 with its release of Internal Revenue...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2022 – April 23, 2022... April 18, 2022: The IRS issued Revenue Ruling 2022-9,...more