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Tax Planning Compliance Income Taxes

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Foley & Lardner LLP

Tricky Compliance Issues for Companies When an Executive Terminates Employment: 409A Applicability to Severance

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Executive employment relationships are rarely permanent. When an executive or other senior-level employee terminates employment, companies often must deal with difficult tax, equity, and benefits issues that arise in...more

Allen Barron, Inc.

International Business Dealings Require Integrated Legal, Tax and Accounting Support

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Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United...more

McDermott Will & Schulte

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

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

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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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

Proskauer Rose LLP

UK Tax Round Up - January 2025

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Welcome to the January 2025 edition of our UK Tax Round Up. This month has seen a very interesting decision of the Court of Appeal on the significant influence test in the salaried member rules and decisions on the tax...more

IR Global

Self-employment cannot be used as a tax smokescreen

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Self-employment cannot be used as a tax smokescreen for contracted employees A complex celebrity case arose recently in which the First-tier Tax Tribunal (FTT) was asked to consider the application of the intermediaries’...more

Cadwalader, Wickersham & Taft LLP

Determining Significant Influence

On 17 January 2025, the United Kingdom Court of Appeal in HMRC v BlueCrest Capital Management (UK) LLP [2025] EWCA Civ 23 (“BlueCrest”) held that the First-tier Tribunal (“FTT”) and the Upper Tribunal (“UT”) had made a...more

Ankura

The Critical Importance of Tax Due Diligence in Modern Business Transactions

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In today's complex and ever-evolving business landscape, tax due diligence has emerged as a critical component of financial analysis and risk management in mergers, acquisitions, and other significant business transactions....more

Proskauer - Tax Talks

Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752

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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

Allen Barron, Inc.

The Appeal of an IRS Audit is Based Upon the Audit's Examination File

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Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more

Husch Blackwell LLP

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

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A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Aim To Overhaul Tax-Free Spin-Off Rules

On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more

Rivkin Radler LLP

Employer to Nonresident Employee: “You Cannot Work in New York”; New York to Employee: “We Will Tax You Anyway”

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You are probably aware that many employers are discarding the fully flexible, remote work policies that were forced upon them – as “nonessential” businesses – during the COVID-19 pandemic[i] and which they retained as an...more

Wilson Sonsini Goodrich & Rosati

Action Required: Share Transfers Pursuant to ISO Exercises and ESPP Purchases

Companies frequently grant incentive stock options (ISOs) or sponsor an employee stock purchase plan (ESPP) to provide tax-advantaged equity incentives to employees that are U.S. taxpayers. One aspect of the tax-advantaged...more

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

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The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

Foley & Lardner LLP

Tax Court Reaffirms Soroban Holding that “Active” Limited Partners are Subject to Self-Employment Tax

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On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...more

Sheppard Mullin Richter & Hampton LLP

Reminder about Annual ISO/ESPP Reporting in January 2025 and New Section 83(b) Election Form

Annual Reporting on ISO/ESPP Transactions - As originally discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require...more

Farrell Fritz, P.C.

Preparing For 2025 Tax Filing Season

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The end of 2024 is quickly approaching, and many are taking a moment (or two) to enjoy the Holiday Season. But as is always the case, after the New Year, taxpayers must turn their attention to tax filing season....more

Oberheiden P.C.

5 IRS Penalty Abatement Strategies

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As a U.S. taxpayer, one of the last things that you want to hear is that the Internal Revenue Service (IRS) has disagreed with your tax assessment and has imposed penalties for noncompliance. The good news is that the IRS...more

Allen Barron, Inc.

Estate and Tax Planning for US Expatriates

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What are the most important elements of estate and tax planning for US expatriates?  Are you planning to move out of the United States?  Are you a US taxpayer who lives and works outside of the country?  What are some of the...more

Gray Reed

IRS Announces New Compliance Efforts Aimed at High-Income Taxpayers, Partnerships, Digital Assets, FBARs and Labor Brokers

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On September 8, 2023, the IRS announced a multitude of compliance initiatives aimed at high-income taxpayers, partnerships, digital assets, FBARs and labor brokers.  According to the announcement, the IRS has finalized its...more

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