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McDermott Will & Schulte

IRS announces intent to withdraw controversial DPL rules

The US Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2025-44, announcing their intent to withdraw the controversial disregarded payment loss (DPL) rules finalized at the end of the...more

Latham & Watkins LLP

One Big Beautiful Bill: Key Business and Investment Impacts

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On July 4, 2025, President Trump signed into law H.R. 1, known as the One Big Beautiful Bill Act (the Act). The Act changes key features of US tax law. Notably, the Act: ..Makes permanent the Section 199A2...more

Kilpatrick

5 Key Takeaways: Business and Nonbusiness Income

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Kilpatrick’s Jordan Goodman recently co-presented the session “Income Subject to Allocation” at the Institute for Professionals in Taxation’s “2025 State Income Tax School” in Atlanta. Jordan addressed the distinction between...more

DLA Piper

What the One Big Beautiful Bill Act’s Tax Provisions Mean for Businesses Operating in Puerto Rico

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President Donald Trump recently signed into law the bill commonly known as the One Big Beautiful Bill Act (OBBBA). On July 4, 2025, the OBBBA made permanent many of the provisions of the Tax Cuts and Jobs Act of 2017 (TCJA)...more

Paul Hastings LLP

REIT All About It: One Big Beautiful Bill — Tax Updates for REITs

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On July 4, 2025, President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law, following the approval of Congress. OBBBA contains the following compelling updates from a real estate investment trust (REIT)...more

Rivkin Radler LLP

Three Big Beautiful M&A Takeaways

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It hasn’t taken long for the business world to start unpacking the implications of the newly passed One Big Beautiful Bill Act (OBBBA). While media coverage has mostly centered on its impact on individual taxpayers and the...more

Stinson LLP

Missouri Eliminates Capital Gains Tax

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On July 10, 2025, Missouri Gov. Mike Kehoe signed House Bill 594, which will exclude both short- and long-term capital gains from Missouri individual income tax and, in certain circumstances, corporate income tax....more

BakerHostetler

[Podcast] An Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more

Kelley Drye & Warren LLP

What’s in the Newly Enacted One Big Beautiful Bill Act

On July 4, 2025, President Trump signed into law the ​“One Big Beautiful Bill Act” (the ​“2025 Act”). The Act makes permanent some provisions originally enacted in 2017 as part of the Tax Cuts and Jobs Act (the ​“2017 Act”),...more

Hone Maxwell

Tax Law Changes in the One, Big, Beautiful Bill Act: Key Takeaways

Hone Maxwell on

The One, Big, Beautiful Bill Act, passed on July 4, 2025, introduces many significant changes to U.S. tax law, affecting individual, estate and gift, business, and international tax provisions. For some of these changes, it...more

Miller Canfield

Business Tax Updates in the One Big Beautiful Bill

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The One Big Beautiful Bill creates and/or modifies a number of tax rules that impact taxation of business income, including the permanent extension of the 20% pass-through deduction under Section 199A and the return of full...more

Holland & Knight LLP

AbbVie's Tax Triumph: Breaking Free from Capital Loss Limitations

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In a significant win for taxpayers, the U.S. Tax Court recently ruled in AbbVie Inc. v. Commissioner, Docket No. 2597-23, that a $1.6 billion "Break Fee" paid by AbbVie qualifies as an ordinary and necessary business expense...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of June 23, 2025

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

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Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more

Lowenstein Sandler LLP

Section 280G Unpacked: Pitfalls and Planning for Tech Startups

In this episode of Just Compensation, Megan Monson and Jessica I. Kriegsfeld talk to Anthony O. Pergola, Vice Chair of Lowenstein’s Emerging Companies & Venture Capital practice group, about the complexities and challenges of...more

Whiteford

Client Alert: Inside the One Big Beautiful Bill Crucial Tax Updates for Individuals, Business Owners, and Nonprofits

Whiteford on

On May 22, 2025, the House of Representatives passed H.R. 1-119th Congress (2025-2026), titled as the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses soon to sunset provisions of...more

Morgan Lewis

Federal Fiscal Court Issues Two Rulings on the Requirements for a Consolidated Tax Group for Income Tax Purposes - Legal Insights...

Morgan Lewis on

In two rulings, the Federal Fiscal Court (BFH) ruled in favor of the taxpayer on the requirements for a consolidated tax group for income tax purposes. Managing holding partnership as controlling company (judgment of November...more

A&O Shearman

House Ways and Means Committee releases draft tax amendments for 2025 Reconciliation Bill

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On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more

McDermott Will & Schulte

Economic Ownership of Shares Transferred as Collateral

Dividends from shares are taxable for shareholders, even if the dividends do not remain with them economically. This (not entirely new) finding can be gleaned from a recent Federal Fiscal Court (BFH) ruling in which the...more

DLA Piper

Top Ten State Tax Considerations for Israeli Companies Operating in the US

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Although Israeli companies operating in the US often focus on federal tax concerns, US state and local taxes (SALT) have the potential to significantly increase tax liabilities. For example, if a company does not collect...more

Keating Muething & Klekamp PLL

Documentation is Key When Claiming QSBS Benefits

In recent years, the utilization of qualified small business stock (“QSBS”) under Section 1202 has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax...more

Akin Gump Strauss Hauer & Feld LLP

2025 Perspectives in Private Equity: Tax Analysis

Major portions of the U.S. tax code are scheduled to expire at the end of 2025, and as the U.S. tax landscape faces potential upheaval, private equity firms must stay vigilant and adaptable. Proactively engaging with tax...more

Farrell Fritz, P.C.

M&A Tax Concepts: What is a “Gross-up Payment,” and Why Does It Matter?

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Buying or selling a business is an exciting experience, and potentially lucrative opportunity for all parties. Most often, during the letter of intent / early negotiations phase, a “deal” is struck based primarily on economic...more

Morrison & Foerster LLP

Koalitionsvertrag 2025 aus steuerrechtlicher Sicht

Die Koalitionsgespräche sind abgeschlossen. Wir geben einen ersten Überblick über die gemeinsamen steuerrechtlichen Ziele, die sich CDU/CSU und SPD als Koalitionspartner gesetzt haben. Die Koalitionspartner planen Änderungen...more

Blake, Cassels & Graydon LLP

Budget 2025-2026 du Québec : Points saillants en matière de fiscalité

Le 25 mars 2025, le ministre des Finances du Québec, Eric Girard, a déposé le budget 2025-2026 du Québec (le « budget 2025-2026 »). Intitulé Pour un Québec fort, ce budget est axé sur des investissements ayant pour but...more

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