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Eversheds Sutherland (US) LLP

Tax Bytes: Week of July 14, 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

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part III – Gambling / Code Section 165(d)

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In this third installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss a provision of the Act that may not impact a large segment of the population, but which is interesting and worthy of...more

Baker Botts L.L.P.

Taxpayer Assistance and Service Act – Comments from the ABA Tax Section

Baker Botts L.L.P. on

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a taxpayer-friendly legislative proposal. While it is uncertain whether the TAS Act...more

Eversheds Sutherland (US) LLP

Georgia’s 2025 legislative session: Tax legislation overview

During the 2025 legislative session, the Georgia General Assembly passed several notable tax related bills including further decreasing the income tax rate and extending the time period for taxpayers to protest and appeal the...more

Baker Botts L.L.P.

Taxpayer Assistance and Service Act – Tax Controversy Perspective

Baker Botts L.L.P. on

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more

Proskauer - Tax Talks

Senators Crapo and Wyden Release Draft Bipartisan Taxpayer Rights Legislation

Proskauer - Tax Talks on

On January 30, 2025, Mike Crapo (R-ID), the Chairman of the Senate Finance Committee, and Senator Ron Wyden (D-OR), the Ranking Member of the Senate Finance Committee released a discussion draft of the “Taxpayer Assistance...more

McDermott Will & Schulte

IRS Roundup February 10 – 14, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS - The previous IRS...more

Fox Rothschild LLP

IRS Layoffs May Mean Longer Waits, Audit Delays and Tax Court Battles

Fox Rothschild LLP on

The Internal Revenue Service (IRS) is expected to lay off approximately 7% of its workforce in the coming weeks, with the possibility of further reductions. It remains unclear which divisions will be most affected or whether...more

Morgan Lewis

Private Funds Year in Review: Key Tax Developments That Shaped the Industry in 2024

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In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more

Eversheds Sutherland (US) LLP

Something old and something new: Final Appeals regulations maintain pre-TFA exclusions from Appeals eligibility; pilot program...

On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more

Baker Donelson

No More Lists – IRS Concedes on Reportable Transaction Penalties

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Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more

McDermott Will & Schulte

Court Rules Taxpayer Can Offset Foreign Tax Credits With NIIT Liability Under Tax Treaty

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In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more

Rivkin Radler LLP

Partnership Losses But No Outside Basis? Too Bad

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Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more

Polsinelli

The IRS is Not Backing Down: Proposed Regulations Issued Regarding Abusive Tax Shelters Including Certain Syndicated Conservation...

Polsinelli on

Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more

Stikeman Elliott LLP

GST/HST Input Tax Credit Claims: Does the Supporting Documentation Need to be Issued by the Supplier?

Stikeman Elliott LLP on

On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

Proskauer Rose LLP on

Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Proskauer Rose LLP

UK Tax Round Up - March 2022

Proskauer Rose LLP on

Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more

Proskauer Rose LLP

UK Tax Round Up - January 2022

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UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more

McDermott Will & Schulte

A Look Back at Supreme Court Justice Breyer's Tax Opinion in Home Concrete

On January 27, 2022, Supreme Court of the United States Justice Stephen Breyer formally announced his retirement, effective when the Supreme Court breaks for summer recess in June or July later this year—after his successor...more

Womble Bond Dickinson

2021 Arizona Tax Updates

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TRANSACTION PRIVILEGE TAX UPDATES LEGISLATION - Senate Bill 1110, Chapter 443. Tribal Exemptions. This bill codified the following exemptions applicable to Indian tribes and tribal members at A.R.S. § 42-5121 et seq.: (1)...more

Proskauer Rose LLP

UK Tax Round Up - December 2021

Proskauer Rose LLP on

UK Case Law Developments - Taxpayer treated as receiving distribution in tax avoidance case - We reported on First-tier Tribunal’s (FTT’s) decision in Dunsby v Revenue & Customs in our June 2020 UK Tax Round Up. By way...more

McDermott Will & Schulte

Second Circuit Weighs in on Tax Court’s Refund Jurisdiction

Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s...more

McDermott Will & Schulte

Tax Court Rules State Corporate Incentives Are NOT Taxable Income Under Federal Law

Many states and localities give incentives for business to move or transact in their locations. There has always been a question of whether these incentives are taxable income under federal income tax law. Internal Revenue...more

Cozen O'Connor

2018 Year-End Tax Update – The Long Goodbye

Cozen O'Connor on

Thanksgiving, 2018 – Bucks County, Pa. - A Brief Look Back - I always know summer is over when I sit down to draft our annual Year-End Tax Update because the leaves are brown, the sky is gray, Rita’s water ice shop is...more

A&O Shearman

Tax Reform Summary for Family Offices

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On December 20, 2017, Congress passed the “Tax Cut and Jobs Act,” which was signed into law by President Trump on December 22, 2017. With some exceptions, the law’s provisions generally are effective for tax years beginning...more

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