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McDermott Will & Schulte

IRS Roundup February 17 – March 14, 2025

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...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

DLA Piper

El Servicio de Impuestos Internos Publica su Catálogo de Esquemas Tributarios 2025

DLA Piper on

Cada año, el Servicio de Impuestos Internos (SII) actualiza la guía denominada Catálogo de Esquemas Tributarios, que contiene un listado de operaciones que pueden ser declaradas elusivas por aplicación de la Norma General...more

DLA Piper

Chile's Internal Revenue Service Publishes It's 2025 Tax Schemes Catalog

DLA Piper on

Each year, the Internal Revenue Service of Chile (SII) updates its Tax Schemes Catalog. This guide contains a list of operations that may be declared elusive by applying the General Anti-Elusiveness Rule. The catalog's...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

Mayer Brown

Prix de transfert : la détermination du taux d'intérêt de référence concernant les avances intragroupe

Mayer Brown on

Dans une décision qui sera mentionnée aux tables du Recueil Lebon, le Conseil d'Etat apporte des précisions relatives au régime de la charge de la preuve en matière de prix de transfert en présence d'avances consenties sans...more

Mayer Brown

Brazilian Tax Reform: Complementary Law No. 214/2025 Sanctioned

Mayer Brown on

On January 16, 2025, Brazil’s president sanctioned Complementary Law No. 214/2025 (CL 214), stemming from the approval of Complementary Bill of Law No. 68/2024 (PLP 68), which establishes the Tax and Contribution on Goods and...more

Fleurinord Law PLLC

The Pros and Cons of Parents Claiming College Students as Dependents

Fleurinord Law PLLC on

As the back-to-school season kicks off and college students begin their fall semester, now is the perfect time to consider the financial implications of your child heading off to college. The decision of whether to claim them...more

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

Hooked on a Feeling! The Benefits of 501(c)(4) Charitable Organizations

I seem to have been on a writing sabbatical for the last year. Over the course of the year, I have discovered a few new planning ideas to share going forward. From previous articles you already know that I grew up in the...more

Mayer Brown

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

Mayer Brown on

In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Gray Reed

FBAR Penalty Defenses and Techniques: The Wrong “Willful” Penalty Computation

Gray Reed on

On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future.  For those unfamiliar with FBARs, federal law requires United States persons to...more

Foodman CPAs & Advisors

How Will Virtual Currency Be Taxed?

Foodman CPAs & Advisors on

Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

Herbert Smith Freehills Kramer

Final Treasury Regulations Clarify Business Interest Deduction Limitation

Background - On July 28, 2020, the Internal Revenue Service (IRS) issued final regulations (T.D. 9905) (the final regulations) concerning the limitation on the deductibility of business interest expense (BIE) under Section...more

Kilpatrick

[Event] North Carolina Legislative Update CLE - February 27th, Cary, NC

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Join Kilpatrick Townsend Government Relations Advisors Ches McDowell and Nelson Freeman for a North Carolina Legislative Update. Ches and Nelson will discuss some of the public bills passed by the General Assembly in the 2019...more

Troutman Pepper Locke

IRS Issues Proposed Regulations On Section 162(M)'s Executive Compensation Deductibility Cap

Troutman Pepper Locke on

On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more

Herbert Smith Freehills Kramer

New Section 162(m) Proposed Regulations

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

Mayer Brown

Final Regulations Published Addressing Income Inclusion Rules for Pass-Through Lease of ITC Property

Mayer Brown on

On July 17, 2019, the US Internal Revenue Service (IRS) issued final regulations (T.D. 9872) providing guidance on the rules under Internal Revenue Code (IRC) section 50(d)(5) requiring an income inclusion by the lessee in...more

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