News & Analysis as of

Taxation

McDermott Will & Schulte

Generative AI chatbot service not subject to Indiana sales tax

In one of the first pieces of administrative guidance addressing the sales tax treatment of generative artificial intelligence (AI) services, the Indiana Department of Revenue (DOR) recently issued a revenue ruling confirming...more

Snell & Wilmer

Local Taxation on Tribal Land in Arizona: An Update

Snell & Wilmer on

On June 30, 2025, the United States Supreme Court denied certiorari in an Arizona taxation case involving tribal sovereignty and preemption. South Point Energy Center, LLC (South Point) submitted a Petition for a Writ of...more

Allen Barron, Inc.

U.S. Expatriates Should Read IRS Publication 54 - Tax Guide for U.S. Citizens and Resident Aliens Abroad

Allen Barron, Inc. on

U.S. expatriates should read IRS Publication 54 - Tax Guide for U.S. Citizens and Resident Aliens Abroad. This is a beneficial article published by the agency itself, detailing the unique and specific tax reporting...more

Brownstein Hyatt Farber Schreck

Deja Vu? Colorado’s Special Session Ends with Budget Tweaks, But Again No Long-Term AI Deal

Last Thursday, Aug. 21, the Colorado General Assembly reconvened for its 2025 Extraordinary Session, mostly focused on addressing the $750‒$800 million state budget shortfall created by the federal government’s passage of the...more

Herbert Smith Freehills Kramer

Luxembourg Reverse Hybrid Entity Rules: Clarifications Regarding the CIV Exemption

On 22 August 2025, the Luxembourg tax authorities issued a second circular (Circular) on the reverse hybrid entity rules, this time clarifying the exemption applicable to collective investment vehicles (CIV Exemption)....more

Baker Donelson

IRS Streamlines 83(b) Election Process with New Online Filing Option

Baker Donelson on

The Internal Revenue Service (IRS) continued recent improvements to the process for making elections under Section 83(b) of the Internal Revenue Code of 1986 (the Code). Until last year, an 83(b) election was made in a...more

Weintraub Tobin

Part 1: The One Big Beautiful Bill Act – Tax Breaks for Tips and Overtime, Bigger SALT deduction, and a Boost to PTET Credits

Weintraub Tobin on

On July 4, 2025 the One Big Beautiful Bill Act (OBBBA) was signed into law.[1] The OBBBA made several provisions permanent from the Tax Cuts and Jobs Act (TCJA). It also made significant changes aimed to expand deductions,...more

Allen Barron, Inc.

Legal Services in a Rapidly Changing World

Allen Barron, Inc. on

Are you searching for a reliable partner to provide legal services in a rapidly changing world? How will legal decisions impact other aspects of your company, including operations, accounting, existing business...more

Akerman LLP - SALT Insights

Not-So-Sweet Home: Alabama Lawsuit Risks Constitutional Challenges to the State’s Sales/Use Tax Regime

In mid-August, Alabama cities and a school district (“localities”) sued the commissioner of the Alabama Department of Revenue seeking, in essence, to “de-simplify” the state’s sales and use tax system. The localities claim...more

Mayer Brown

Brasília em Pauta – Edição Nº 209

Mayer Brown on

Prezados e prezadas, O “Brasília em Pauta” é um boletim semanal preparado pela equipe de Contencioso de Brasília, contendo os principais casos a serem julgados pelo Supremo Tribunal Federal (STF), Superior Tribunal de...more

Latham & Watkins LLP

French Tax Authorities’ Guidelines Clarify the New Legal Framework Applicable to Management Package Instruments

Latham & Watkins LLP on

The regime sets new rules regarding the taxation of gains realized on the sale of securities held by employees or executives in the frame of management packages....more

Eversheds Sutherland (US) LLP

Entering the Digital (Asset) Age: White House Report Recommends Changes to the Taxation of Digital Assets

The President’s Working Group on Digital Asset Markets recently issued a detailed report, titled “Strengthening American Leadership in Digital Financial Technology,” recommending regulatory and legislative proposals to...more

Mayer Brown

Tax Law Highlights - Impact of the Tax Reform on Administrative and Judicial Litigation: Jurisdiction and Related Issues

Mayer Brown on

ADMINISTRATIVE LITIGATION - Introduction: Tax Reform and the Possible Increase in Litigation; Operation of IBS tax inspection...more

Pillsbury - SeeSalt Blog

Putting Regulations to the Test: California Taxpayers Cleared to Challenge Regulations in OTA Appeals

The California Attorney General has confirmed the Office of Tax Appeals (OTA) may decline to apply a tax regulation in a taxpayer appeal if it conflicts with the relevant statute. OTA must afford appropriate deference to the...more

Cadwalader, Wickersham & Taft LLP

Trump’s Crypto White Paper Talks Tax!

On July 30, 2025, the Trump Administration issued an expansive report on the crypto industry (the “White Paper”), describing the digital asset landscape and outlining the contours of a legislative and regulatory framework....more

Fox Rothschild LLP

DOJ Tax Division Leader Departs Amid Large-Scale Reorganization

Fox Rothschild LLP on

The head of the Justice Department’s Tax Division has departed for private practice, just as the planned dismantling of the Tax Division was set to take place. Karen Kelly, who served as acting deputy assistant attorney...more

Paul Hastings LLP

German Federal Fiscal Court Questions Double RETT on Share Deals

Paul Hastings LLP on

Germany’s Federal Fiscal Court (BFH) has decided on the legitimacy of double assessment of real estate transfer tax in share deals. Tax authorities have taken the view that the acquisition of at least 90% of shares in a...more

Mayer Brown

Brasília em Pauta - Edição Nº 208

Mayer Brown on

O “Brasília em Pauta” é um boletim semanal preparado pela equipe de Contencioso de Brasília, contendo os principais casos a serem julgados pelo Supremo Tribunal Federal (STF), Superior Tribunal de Justiça (STJ) e Tribunal de...more

Cadwalader, Wickersham & Taft LLP

Wyden’s Partnership Tax Bills: A Mouthful and Then Some

On June 17, 2025, Senator Ron Wyden introduced two extensive partnership tax reform bills in the Senate (collectively, the “Bills,” and available here and here).  The Bills expanded upon and incorporated many of Wyden’s 2021...more

McDermott Will & Schulte

Carried interest in the UK: The new average holding period (AHP) condition for credit funds

The UK tax regime for carried interest is being substantially revised from April 2026. This Alert focuses on one particular aspect: the changes to how credit funds should calculate the average holding period (AHP) of their...more

Fox Rothschild LLP

IRS Leadership Turmoil Intensifies as Commissioner Billy Long Is Removed After Just Two Months

Fox Rothschild LLP on

On August 8, President Donald Trump abruptly removed Billy Long from his position as Commissioner of Internal Revenue, making Long’s tenure the shortest for a Senate-confirmed commissioner in the tax agency’s 162-year...more

McDermott Will & Schulte

Fourth Circuit strikes down Maryland’s digital ad tax “pass-through” ban

Maryland’s attempt to stop businesses from telling customers about a controversial tax has hit a constitutional wall. On August 15, 2025, the US Court of Appeals for the Fourth Circuit ruled that the state’s “pass-through”...more

Hogan Lovells

HL UK Pensions Law Digest 19 August 2025

Hogan Lovells on

A bite-sized summary of recent UK pension news Welcome to our latest update, in which we cover: Tax on benefits paid overseas A recent Tribunal decision that a transfer from a UK occupational scheme to a UK SIPP did not...more

Vorys, Sater, Seymour and Pease LLP

Ohio General Assembly Makes Changes to Real Property Complaint Process

Substitute House Bill 96 (H.B. 96), Ohio’s operating appropriations bill for fiscal years 2026 –-2027, was passed by the General Assembly on June 25, 2025 and signed by Ohio Governor Mike DeWine on June 30, 2025. The...more

Vorys, Sater, Seymour and Pease LLP

Ohio Supreme Court Doubles Down on Applying a Plain and Ordinary Meaning to Sales Tax Exemptions

On August 13, 2025, the Ohio Supreme Court overturned the Ohio Board of Tax Appeals (BTA) and the Ohio Tax Commissioner in Claugus Fam. Farm, L.P. v. Harris, 2025-Ohio-2807, Slip Opinion No. 2025-Ohio-2807, thereby allowing...more

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