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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 Rose LLP

Wealth Management Update - March 2025

Proskauer Rose LLP on

March 2025 AFRs and 7520 Rate - The March 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.40%, which was the same as the February 2025 rate...more

Husch Blackwell LLP

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

Husch Blackwell LLP on

A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Rivkin Radler LLP

Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?

Rivkin Radler LLP on

Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more

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