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Tax Planning Excise Tax

McCarter & English, LLP

One Big Beautiful Bill Act Tax Law Updates–Private Educational Institutions and Nonprofits

On July 4, 2025, President Trump signed into law legislation commonly referred to as the “One Big Beautiful Bill Act” (OBBBA), which includes provisions that specifically affect private primary, secondary, and post-secondary...more

Miller Canfield

One Big Beautiful Bill: Effect on Exempt Organizations

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The sweeping tax package known as the One Big Beautiful Bill (OBBB), which passed on July 3 and was signed by President Donald Trump by July 4, brings notable changes for tax-exempt organizations, including new limits on...more

Jackson Lewis P.C.

Employers Who Administer PFML Programs Get Much-Needed Guidance from IRS

Jackson Lewis P.C. on

In response to taxpayer and state government requests, including a 2024 letter from governors of nine states imploring the Internal Revenue Service (IRS) to clarify the federal tax treatment of premiums and benefits under...more

McDermott Will & Schulte

Weekly IRS Roundup August 5 – August 9, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5, 2024 – August 9, 2024. August 5, 2024: The IRS released Internal Revenue Bulletin 2024-32,...more

Gray Reed

IRS Targets Charitable Remainder Annuity Trusts (CRATs) as Listed Transactions

Gray Reed on

On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions.  For those unaware of the listed transaction rules, such a designation would...more

Cadwalader, Wickersham & Taft LLP

IRS Releases Proposed Donor-Advised Fund Regulations

The IRS recently released proposed regulations interpreting the provisions of the Code pertaining to donor-advised funds ("DAFs"). The regulations provide needed definitions of working terms such as DAFs, Donors and...more

McGuireWoods LLP

Donor Advised Funds: Proposed Regs Offer Guidance, But Leave Big Questions Unanswered

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For the past 16 years, the U.S. Department of the Treasury’s Office of Tax Policy and the Internal Revenue Service’s joint Priority Guidance Plan has included the issuance of regulations relating to donor advised funds (DAFs)...more

Baker Donelson

Summaries Released of Select Informal Conference Decisions

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The Tennessee Department of Revenue (Department) recently posted certain selected informal conference summaries which provides taxpayers with insight into how the Hearing Office will address various issues arising under...more

Baker Donelson

SALT Select Developments - February 2024

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

McDermott Will & Schulte

The Tax Implications of Purchasing Craft Producers in the First Half of a Year

If a large beverage company is considering purchasing or selling a craft beverage producer, it’s essential to understand how the craft producer may lose its earlier eligibility for reduced tax rates under the Craft Beverage...more

Baker Donelson

SALT Select Developments - May 2023

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain state and local tax (SALT)...more

A&O Shearman

Funding Rule Under Notice 2023-2 Expands the Scope of the Stock Buyback Excise Tax to Repurchases of Stock of Many Foreign...

A&O Shearman on

Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more

Miller Nash LLP

Washington’s New Capital Gains Excise Tax: An Income Tax by Another Name

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The Washington State Supreme Court recently upheld an excise tax on the privilege of selling capital assets within the State of Washington. The Court upheld the new tax over concerns that the tax violated both the state and...more

Baker Donelson

SALT Select Developments - March 2023

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain state and local tax (SALT)...more

McDermott Will & Schulte

Weekly IRS Roundup January 17 – January 20, 2023

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 17, 2023 – January 20, 2023...more

McDermott Will & Schulte

Weekly IRS Roundup December 19 – December 23, 2022

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 19, 2022 – December 23, 2022...more

Troutman Pepper Locke

Practical Tips for Avoiding and Contesting Tobacco Tax Assessments

Troutman Pepper Locke on

Dealing in goods subject to cigarette and other tobacco products (OTP) taxes presents considerable administrative burdens. The sale of cigarettes and other tobacco products, on which all 50 states impose an excise tax,...more

Freeman Law

Moments in Tax History | The Child Labor Tax Case | What’s a Tax?

Freeman Law on

Bailey v. Drexel Furniture Co., 259 U.S. 20 (1922) (a/k/a “Child Labor Tax Case”) - Summary: In the Child Tax Labor Case, the U.S. Supreme Court ruled that a purported “tax” was really a “penalty” and therefore an...more

Wilson Sonsini Goodrich & Rosati

The New One-Percent Excise Tax on Stock Repurchases and Its Potential Implications for Convertible Bond Hedge Transactions and...

On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the "Inflation Reduction Act" (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more

Freeman Law

Tax Court in Brief | Couturier v. Commissioner | Taxation of Excess Contributions from IRA

Freeman Law on

Tax Litigation: The Week of July 4th, 2022, through July 8th, 2022 Barrington v. Commissioner, T.C. Memo. 2022-68 | July 6, 2022 | Buch, J.| Dkt. No. 1781-14 Wolpert v. Commissioner, T.C. Memo. 2022-70 | July 7, 2022 |...more

Foster Garvey PC

Disregarded Entities Under the Check-the-Box Regulations Are Not Disregarded for All Tax Purposes

Foster Garvey PC on

More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). The Regulations ended decades of battles between taxpayers and the IRS over entity...more

Holland & Knight LLP

Infrastructure Investment and Jobs Act Revitalizes Superfund Tax on Chemicals (Update)

Holland & Knight LLP on

The Infrastructure Investment and Jobs Act (IIJA), signed by President Joe Biden on Nov. 15, 2021, revives an excise tax last effective in 1995 on the sale or use of 42 identified chemicals as well as certain substances...more

Bergeson & Campbell, P.C.

Reinstated Superfund Excise Tax Imposed on Certain Chemical Substances

On November 15, 2021, President Biden signed into law the Infrastructure Investment and Jobs Act (IIJA), Public Law 117-58, 135 Stat. 429. Section 80201 of the IIJA reinstates the Superfund excise tax on certain chemical...more

Proskauer - Tax Talks

A New(ish) Chemical Excise Tax Effective July 2022

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After a more than 26 year hiatus, on July 22, 2022, the Superfund chemical excise tax (the “Superfund Chemical Tax”) will again become effective. This excise tax, reinstated by the passage of the Infrastructure Investment and...more

Freeman Law

Bankruptcy and IRC Section 4980H

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The recent bankruptcy case of In re Creative Hairdressers, Inc. et al, Case Nos. 20-14583 and 20-14584 (jointly administered) (Bankr. D. Md., March 3, 2022) involved the intersection of IRC section 4980H‘s employer shared...more

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