News & Analysis as of

Tax Planning

Jackson Walker

One Big Beautiful Bill Act Increases Deduction for State and Local Tax but Fails to Address Nexus Concerns

Jackson Walker on

In welcome news for individual taxpayers, the One Big Beautiful Bill Act temporarily increases the “SALT cap” – the limit on the amount of the income tax deduction for state and local income, sales, and property taxes – from...more

Jackson Walker

The One Big Beautiful Bill’s New Qualified Opportunity Zones

Jackson Walker on

Under the One Big Beautiful Bill Act (the “OBBBA”), the qualified opportunity zone (QOZ) program will no longer sunset on December 31, 2026, as was set to be the case prior to the act’s passage. Instead, the OBBBA makes this...more

Dickinson Wright

Tax Planning Misstep? Ontario Court of Appeal Says No to Rectification

Dickinson Wright on

A recent decision from the Ontario Court of Appeal is a good reminder that courts won’t bail you out just because a tax plan didn’t go as expected. In Pyxis Real Estate Equities Inc. v. Canada, 2025 ONCA 65, the Court made it...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part VII – The Rules Relating to the Deductibility of Individual...

Foster Garvey PC on

In this seventh installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss provisions of the Act that impact the deductibility of individual charitable gifts under Code Section 170....more

Rivkin Radler LLP

The Enactment of OBBBA: It’s Time to Plan, Not Relax – “Winter is Coming”

Rivkin Radler LLP on

In the months preceding the general election in 2024, the owners of many closely held businesses who had not yet given much thought to the disposition of their future estates, including their businesses, decided they should...more

Davidoff Hutcher & Citron LLP

Trusts as Asset Protection Tools for Restaurant Owners

For restaurant owners, protecting business and personal assets from lawsuits, creditors, and financial risks is essential. One of the most effective legal strategies is using trusts to shield wealth and ensure long-term...more

Stark & Stark

Three Common Estate Planning Mistakes - and How to Avoid Them

Stark & Stark on

​​​​​​​Estate planning is a vital step in protecting your legacy and ensuring your loved ones are protected. Yet, many individuals unintentionally make mistakes that can lead to confusion, delays, and unnecessary expenses....more

Mintz - Tax Viewpoints

New Electronic Filing Option for Section 83(b) Elections

Mintz - Tax Viewpoints on

On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more

Haynes Boone

Federal Estate, Gift and GST Tax Highlights from the One Big Beautiful Bill Act

Haynes Boone on

The recently enacted One Big Beautiful Bill Act (OBBBA) brings sweeping and permanent changes to the federal estate, gift and generation-skipping transfer (GST) tax landscape. Most notably, it significantly increases the...more

Cozen O'Connor

The Big Beautiful Bill: What Every High Net Worth Family Needs to Know

Cozen O'Connor on

The One Big Beautiful Bill Act (OBBBA), signed by President Donald Trump on July 4, 2025, brings sweeping changes to the tax code. While the name may sound like a marketing pitch, the law itself includes significant updates...more

Carey Olsen

Guernsey funds – special considerations for US managers

Carey Olsen on

Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more

Morgan Lewis

Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

Morgan Lewis on

Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more

Eversheds Sutherland (US) LLP

IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs

On July 25, 2025, the IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (Control Number: LB&I-04-0725-0008) implementing changes for LB&I audit procedures, which take effect August 1,...more

A&O Shearman

Key considerations for forming and operating a joint venture in the U.S.

A&O Shearman on

Each of these items will help ensure that a U.S.-based joint venture (JV)—especially one in a regulated industry with cross-border aspects—is set up and operated on solid legal, compliance, and tax footing. By diligently...more

White & Case LLP

Goodbye to the IRS AOF Information Document Request

White & Case LLP on

On July 23, 2025, the Internal Revenue Service ("IRS") issued interim guidance announcing changes to the Large Business & International Division ("LB&I") audit procedures (see the IRS's memorandum, here). The changes aim to...more

Eversheds Sutherland (US) LLP

IRS Removes Willfulness Checkbox from Form 14457, Easing Path for Voluntary Disclosures

In a significant policy shift, the IRS has revised Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the cornerstone of its Voluntary Disclosure Practice (VDP), by removing the controversial...more

Hone Maxwell

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

Hone Maxwell on

Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Roth Catch-Up Chaos is coming

Plan sponsors and recordkeepers let out a collective sigh of relief when the Roth catch-up contribution requirement under SECURE 2.0 was delayed until 2026. And for good reason—this rule, though well-intentioned, brings with...more

Jackson Lewis P.C.

New Tax-favored Benefit for Employees with Children

Jackson Lewis P.C. on

Among the federal tax changes made by the “One Big Beautiful Bill Act” (discussed in our prior post) is a new kind of custodial savings account for children (who’ve been issued a social security number) to which their or...more

Bilzin Sumberg

Section 1202 – Enhanced Opportunities in Increased Exclusions and Caps

Bilzin Sumberg on

Prior to the One Big Beautiful Bill Act signed by President Trump on July 4, 2025 (the “OBBBA”) , Section 1202 provided that non-corporate taxpayers that acquired qualified small business stock after August 10, 1993 (“QSBS”)...more

Mandelbaum Barrett PC

Can I Give My Kids $19,000 a Year and Apply for Medicaid?

Mandelbaum Barrett PC on

If you have money to give your children, you certainly can, but you should be aware that you may face consequences should you apply for Medicaid long-term care coverage within five years after each gift. Medicaid’s rules...more

Hogan Lovells

UK carried interest regime: draft legislation confirms scope and conditions

Hogan Lovells on

On 21 July 2025, the UK Government published draft legislation for the new UK carried interest regime, which is expected to come into effect from 6 April 2026. As previously announced, the draft legislation provides for...more

Ropes & Gray LLP

French Tax Administration Issues Draft Comments on Management Package Tax Reform

Ropes & Gray LLP on

On July 23, 2025, the French Tax Administration released its initial draft guidance in the BOFiP (Bulletin Officiel des Finances Publiques) (the “Tax Comments”) on the new tax regime for Management Packages introduced by the...more

Hughes Hubbard & Reed LLP

Expansion of Qualified Small Business Stock Tax Benefits

On July 4, President Donald Trump signed a budget reconciliation bill entitled the “One Big, Beautiful Bill Act” (the Act). The Act extends the tax cuts that were enacted as part of the Tax Cuts and Jobs Act of 2017, adds a...more

Tonkon Torp LLP

Three Tips to Optimize Your Succession Planning

Tonkon Torp LLP on

You’ve put the proverbial blood, sweat and tears into building your business. You’ve navigated its challenges and celebrated its growth. You may even have plans for what’s next — but are you planning for when you’re no longer...more

4,229 Results
 / 
View per page
Page: of 170

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide