News & Analysis as of

Tax Liability Tax Code

Shumaker, Loop & Kendrick, LLP

The Estate Planner, July/August 2025

Handle an inherited IRA with care - An inherited IRA can be a welcome financial windfall. But the rules governing required minimum distributions (RMDs) from these tax-deferred accounts are complex. IRA recipients should...more

Freeman Law

Risks in Avoiding State Tax Obligations

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When a business has been hit with substantial tax liability, it can often be tempting to pack things up and abandon the business. Often, taxpayers consider the possibility of opening a new business in its place, as a means...more

DLA Piper

Chile Publishes Instructions on Appraisal Authority and its Application to Corporate Reorganizations

DLA Piper on

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

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

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Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | February 2025

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Welcome back to the buzz, our monthly cannabis news and policy update. Your at-a-glance source for regulatory developments, agency announcements, and trends impacting the cannabis industry. In this edition of the buzz,...more

Allen Barron, Inc.

How Often to Review Your Trust and Estate Plan

Allen Barron, Inc. on

How often should you review your trust and estate plan? Is there a regular cycle to these reviews, or should they be driven by significant events in your life or the lives of your beneficiaries and executor or trustee? How...more

Allen Barron, Inc.

The Taxpayer Bill of Rights - 10 Essential Rights for U.S. Taxpayers

Allen Barron, Inc. on

Are you aware of the Taxpayer Bill of Rights?  We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more

Freeman Law

Texas Sales and Use Tax Nexus

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I discussed Texas franchise tax nexus in a prior post, which can be found here. However, there is a different (albeit similar) set of rules for Texas sales and use tax nexus. As with Texas franchise tax nexus, a business...more

Crunched Credit

Time to Fix REMIC:  Grand Bargain Part II

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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

Cadwalader, Wickersham & Taft LLP

Liberty Global Appeals Economic Substance Doctrine Ruling

In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...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

Cadwalader, Wickersham & Taft LLP

The Supreme Court Has Saved the Tax Code for Now and Left Room for Moore

In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT), saving a significant portion of the current tax code for now. The question in front of the Court was whether...more

Mayer Brown

Measure ULA Update: Reported Revenue, Applicability to Foreclosures and Legal Challenges

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In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...more

Bowditch & Dewey

Spousal Relief From Joint Tax Liability

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As a general rule, when a married couple files a joint tax return, they are jointly and severally liable for the entire tax. But what happens if one spouse failed to report income and the other spouse did not know or have...more

Kelley Drye & Warren LLP

Court of Appeals Reverses Tax Court’s Farhy Decision, But Opportunities Remain to Challenge Penalties for Failures to Report...

As noted in our prior advisory, U.S. citizens and residents who receive gifts exceeding certain thresholds from foreign persons must generally report such gifts to the IRS on Form 3520, and the IRS does not hesitate to impose...more

Morgan Lewis

Biden Highlights IRS Plans to Audit Corporate/Partnership Jet Use in State of the Union Address

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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

Williams Mullen

Hoops, LP: Seventh Circuit Denies Deferred Compensation Deduction in Taxable Asset Sale - Upsetting Common Understanding of Timing...

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On August 9, 2023, the Seventh Circuit Court of Appeals in Hoops, LP and Heisley Member, Inc., Tax Matters Partner vs. Commissioner of Internal Revenue, affirmed the Tax Court’s 2022 decision denying a deduction to a plan...more

Nossaman LLP

Los Angeles Office of Finance Clarifies Exemptions from “Mansion Tax”

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The Los Angeles Office of Finance (Office of Finance) has released a new FAQ confirming that real property transfers that are exempt from the current City documentary transfer tax (to which the FAQ refers as the “Base Tax”)...more

Holland & Knight LLP

DIAN Colombia: No compensación de pérdidas en integración de sucursales de sociedad extranjera

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En Oficio #1356 del 9 de noviembre de 2022, la Dirección de Impuestos y Aduanas Nacionales (DIAN) señaló que la integración en Colombia de dos sucursales de sociedades extranjeras, como resultado de una fusión entre sus dos...more

Freeman Law

Tax Residency Status Modification: Mexican Tax Implication

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For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living. And in an increasingly global...more

Freeman Law

Texas Tax Roundup | November 2022: What’s a Franchise Tax?

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Hey everybody! Welcome back to another for another edition of Texas Tax Roundup! Hope y’all had a happy Thanksgiving! We got some franchise tax apportionment, some sales and use tax in the oil and gas industry, and some...more

Allen Matkins

Attention Property Owners: Los Angeles and Santa Monica Approve ‘Mansion Tax’ Ballot Measures, Increasing Transfer Taxes on Sales...

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Residents of Los Angeles have approved Measure ULA, a ballot measure widely known as the “Mansion Tax,” which increases transfer tax rates on real estate sales valued at $5 million or more. Prior to Measure ULA, real estate...more

Cadwalader, Wickersham & Taft LLP

Getting the Fiats Straight: CJEU Annulled State Aid Decision against Fiat

On 8 November 2022, the Court of Justice of the European Union (the “CJEU”) set aside the EU General Court’s judgment of 2019 and annulled the European Commission’s State aid decision of 2015, which held that Luxembourg...more

Franczek P.C.

Illinois Dept. of Revenue Releases Final 2021 Cook County Equalization Factor

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On Tuesday, the Illinois Department of Revenue released the final 2021 Cook County equalization factor.  The factor (sometimes referred to as the multiplier) for 2021 is 3.0027.  The tentative factor released in June was...more

Paul Hastings LLP

Tax Avoidance or Not: Restructuring of Multinational Group Companies with use of Intra-group Loan — Deductibility of Interest...

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Transactions within a corporate group can sometimes achieve reduction of tax obligations, regardless of whether or how much such result was intended. One typical way observed is to extend an international intra-group loan by...more

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