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]
An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more
Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more
Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more
On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more
The US Department of the Treasury and the Internal Revenue Service (IRS) have released Final Regulations related to the resolution of federal tax controversies by the Independent Office of Appeals (Appeals), largely rejecting...more
President Trump is meeting with Republican lawmakers to discuss potential tax code changes, including a proposal to eliminate the carried interest tax break. White House Press Secretary Karoline Leavitt announced the...more
On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership...more
The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...more
The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more
Under recent accounting rule changes, unrealized crypto gains must generally be reported on income statements, but questions arise about the alignment of the new Corporate Alternative Minimum Tax with constitutional tax...more
The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more
It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign (i.e., non-U.S.) company, be a beneficiary of a foreign...more
On March 5, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment election of the advanced manufacturing investment credit...more
The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may make an elective payment, which will treat certain eligible...more
How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more
On March 5, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment of certain tax credits (direct pay) pursuant to Section 6417 of the...more
On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry. By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more
On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more
A new program offers rulings in 12 weeks, even absent a showing of business need. Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more
In a recent article, we observed that the Treasury and the Internal Revenue Service (“IRS”) could address the complex tax issues presented by emerging digital assets either by developing a cohesive framework for taxing these...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
Treasury Department and IRS Release Preliminary Guidance on Semiconductor Tax Credit. On March 23, the Treasury Department and IRS published proposed regulations for implementing the new section 48D advanced manufacturing...more
On December 27, 2022, Treasury issued Notice 2023-7, which provides guidance regarding the new Corporate Alternative Minimum Tax (“CAMT”) that taxpayers can rely on until Treasury publishes additional guidance. As mentioned...more