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Tax Planning Regulatory Reform

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

Hanson Bridgett

Timing is Everything for QSBS After the One Big Beautiful Bill Act

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The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, establishes new phased-in benefits for Qualified Small Business Stock (QSBS) held for at least three years. ...more

Burr & Forman

Georgia House Bill 586 Expands Loan Flexibility and Tax Exemptions

Burr & Forman on

On May 9, 2025, Governor Brian Kemp signed into law House Bill 586, which significantly amends Georgia’s intangible recording tax provisions. Effective July 1, 2025, the bill extends the maturity threshold for “short-term...more

Sheppard Mullin Richter & Hampton LLP

Understanding the Federal Reconciliation Bill’s Implications for MCO Tax Structure

New York’s Medicaid financing strategy—particularly its use of a managed care organization (MCO) tax—has come under renewed federal scrutiny amid recent legislative proposals and regulatory developments. The federal...more

Cadwalader, Wickersham & Taft LLP

IRS Shifts Position on Basis-Shifting Regulations

On April 17, the Internal Revenue Service issued a notice announcing its plans to withdraw a set of controversial regulations, finalized in January of this year, aimed at transactions designed to shift tax basis in...more

Cadwalader, Wickersham & Taft LLP

For 2025, Crypto Taxpayers Can Get Their Ducks in a Row; But Senator Cruz Says “Nyet” to DeFi Regs

Last year, the Treasury and IRS released two sets of final crypto reporting regulations. The first set, in July, imposed rules for custodial brokers. The second set, in December, imposed rules for DeFi. This piece provides...more

Cadwalader, Wickersham & Taft LLP

New York State Bar Association Tax Section Proposes Withdrawal of Proposed Spin-Off Regulations

On March 17, the Tax Section of the New York State Bar Association (the “Tax Section”) released a report on the proposed regulations on corporate spin-offs and reorganizations that were issued in January. As we discussed...more

Hogan Lovells

French supreme Court, March 20, 2025, Alexion Pharma France: a historic turnaround for the financial regulation of French...

Hogan Lovells on

In a decision of 20 March 2025 (Appeal No. N 22-23.927), the FR supreme Court ruled that the “product clawbacks” negotiated with the Economic Committee for Health Products (‘CEPS’) on the price of pharmaceutical products...more

Hogan Lovells

What's new in the UK Pensions legal landscape? 24 March 2025

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This update covers: On 20 March last week, the Finance Bill received Royal Assent and became the Finance Act 2025. The provisions relevant to pensions make changes to: Further details are given below....more

Eversheds Sutherland (US) LLP

San Francisco’s proposed regulation imitates California’s proposed regulation

In November 2024, voters approved Proposition M which provided for an overhaul of San Francisco’s gross receipts tax. Proposition M changed the allocation and apportionment rules for most industries, generally requiring that...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Implications of Trump’s Recent Executive Actions

President Donald Trump has issued a series of executive orders with significant tax implications. The moves underscore the administration’s commitment to influencing tax policies, regulatory frameworks and trade practices as...more

Mayer Brown

STF Establishes Non-Incidence of ISS on Commissioned Manufacturing Activities

Mayer Brown on

The Brazilian Supreme Court (STF) decided that the Tax on Services’ (ISS) non-levy on toll commissioned manufacturing activities, whenever these activities refer to the intermediary activities of a production cycle. The...more

Morrison & Foerster LLP

Treasury Department Shifts CTA to Foreign Entities

As we recently reported, the Financial Crimes Enforcement Network (FinCEN) has been chipping away at the CTA, including through a recent notice. Now, Treasury has dramatically changed the CTA landscape with respect to U.S....more

Gerald Nowotny - Law Office of Gerald R....

Old Days – Memories of Equity Split Dollar in the Post-Loper Bright Era

This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more

Skadden, Arps, Slate, Meagher & Flom LLP

Trump Revives and Expands the Battle Over Digital Services Taxes

On February 21, 2025, President Donald Trump issued a presidential memorandum (the Memorandum) signaling that his administration intends to take action with respect to tax and regulatory measures affecting U.S. digital...more

DLA Piper

White House Executive Orders Impacting Tax and Trade – Developments of the Week of January 27, 2025

DLA Piper on

A range of White House Executive Orders (EOs) are likely to impact tax and trade policy. In this alert, DLA Piper’s Tax and Trade policy team provides updates and insights on relevant policy developments from the week of...more

Farrell Fritz, P.C.

Additional Real Property Tax Relief for Certain Senior Housing Properties in Nassau County Signed into Law

Farrell Fritz, P.C. on

New York State Governor Kathy Hochul signed NYS Senate Bill 8647 (Martins)/Assembly Bill 10355 (Stern) into law this week....more

Mandelbaum Barrett PC

No Need to Be Insecure About Your Retirement Plan: A Guide to SECURE Act 2.0

Mandelbaum Barrett PC on

In July of 2019, the Setting Every Community Up for Retirement Enhancement Act, also known as the SECURE Act, changed the rules pertaining to 401(k), Roth, IRA, and other retirement savings plans. In December of 2022, the...more

Polsinelli

$1.7 Trillion Spending Bill Drops the Hammer on Conservation Easements

Polsinelli on

Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more

Morgan Lewis

‘Securing’ Your Safe-Harbor Plan: IRS Provides Guidance on SECURE Act Changes Affecting Safe-Harbor Plans

Morgan Lewis on

Notice 2020-86 (Notice) from the Internal Revenue Service (IRS) provides guidance to help interpret and apply certain Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) provisions that impact...more

Hogan Lovells

Election 2020 Snapshot: Helping our real estate clients make sense of the U.S. election results

Hogan Lovells on

While there is an anticipation of greater predictability under a President Joe Biden, which is critically important to the commercial real estate industry, expected and potential changes in trade, taxation, housing and health...more

Pullman & Comley, LLC

COVID-19 and Your Retirement Account: Time to Explore Distribution Opportunities?

Pullman & Comley, LLC on

New rules for retirement accounts under the SECURE (Setting Every Community Up for Retirement Enhancement) Act and the CARES (Coronavirus Aid, Relief, and Economic Security) Act, may have a dramatic impact on the optimal...more

Farrell Fritz, P.C.

Wills, Trusts & Estates: Plain and Simple – New Retirement Account Rules: Should You Re-Visit Your Estate Planning Documents?

Farrell Fritz, P.C. on

Under the SECURE act, which was passed by Congress just before Christmas, the new starting age to take Required Minimum Distributions (“RMD’s”) from tax-deferred retirement accounts (exs. an IRA, a 401(k), hereinafter “IRAs”...more

Downs Rachlin Martin PLLC

Significant Changes to Required Minimum Distributions from Inherited Retirement Accounts May Affect your Estate Plan

Effective January 1, 2020, the rules regarding distributions from inherited retirement accounts have changed significantly. Under prior law, a so-called “designated beneficiary” of a retirement account could receive...more

Morgan Lewis - ML Benefits

SECURE Act May Pave Way to More Lifetime Income Opportunities in Defined Contribution Plans

Ever since defined contribution plans have come to dominate the retirement plan landscape, both plan sponsors and policymakers have grappled with how to help employees take a lifetime’s worth of savings and convert it into a...more

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