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Taxation Income Taxes

Latham & Watkins LLP

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

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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

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

Eversheds Sutherland (US) LLP

Eversheds Sutherland SALT Scoreboard - Quarter 2, 2025

This is the second edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of significant taxpayer wins and losses and analyzed those results. This edition includes developments...more

Frost Brown Todd

Section 1202 and QSBS: A Survey of States That Don’t Conform to the Federal Treatment

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Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more

ASKramer Law

Tax-Loss Harvesting Part III: Investment Strategies

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Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment  returns, while offsetting...more

Bricker Graydon LLP

The Legal Ramifications of NIL Deals

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Since the NCAA lifted its restrictions in 2021, student-athletes have been able to profit from their name, image, and likeness (“NIL”), sparking a major shift in college athletics. Compensation for student-athletes has...more

Littler

Recent U.S. Tax Court Opinion Illustrates How Language in Settlement Agreements Can Determine Tax Treatment of Payments

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In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more

Jackson Walker

One Big Beautiful Bill Act Increases Deduction for State and Local Tax but Fails to Address Nexus Concerns

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In welcome news for individual taxpayers, the One Big Beautiful Bill Act temporarily increases the “SALT cap” – the limit on the amount of the income tax deduction for state and local income, sales, and property taxes – from...more

Goodwin

Carried Interest 2.0: Luxembourg Modernises Its Tax Treatment for Fund Managers

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On 24 July 2025, a draft bill (the Bill) proposing significant amendments to the law of 4 December 1967 on income tax and the law of 12 July 2013 on alternative investment fund managers (AIFMs) was submitted to the Luxembourg...more

Mintz - Tax Viewpoints

New Electronic Filing Option for Section 83(b) Elections

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On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more

Hogan Lovells

UK carried interest regime: draft legislation confirms scope and conditions

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On 21 July 2025, the UK Government published draft legislation for the new UK carried interest regime, which is expected to come into effect from 6 April 2026. As previously announced, the draft legislation provides for...more

Kilpatrick

6 Key Takeaways: Fundamentals of Formulary Apportionment

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Kilpatrick’s Jordan Goodman recently co-presented the session “Fundamentals of Formulary Apportionment” at the Institute for Professionals in Taxation’s “2025 State Income Tax School” in Atlanta. Jordan addressed the basic...more

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

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At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more

Latham & Watkins LLP

The UK’s New Regime for Carried Interest Taxation - How the Draft Legislation Stacks Up

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On 21 July 2025, the UK government published draft legislation relating to its new carried interest regime. This Client Alert considers key aspects of the new regime and how it may apply to UK-based asset managers and non-UK...more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Cadwalader, Wickersham & Taft LLP

Beard v HMRC: Capital Dividends. A Triumph of Form Over Substance?

Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more

Cadwalader, Wickersham & Taft LLP

House Ways and Means to Crypto’s Rescue on Taxes?

On July 16, 2025, the House Ways and Means Committee held a hearing on crypto taxation. Congress and the Administration did not address tax issues in the most recent Digital Asset legislation, as previously discussed here. ...more

Blank Rome LLP

One Big Beautiful Bill Act: Key Business, International, and Employment Tax Provisions

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The federal government enacted the One Big Beautiful Bill Act (the “Act”) on July 4, 2025. The Act extends and makes permanent certain tax provisions introduced in the Tax Cuts and Jobs Act (the “TCJA”) that were scheduled to...more

Proskauer - Tax Talks

President Trump Signs One Big Beautiful Bill Act into Law

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. The Act is similar to the Senate Finance Committee’s draft legislative text (the “SFC Bill”) (released on June 16, 2025), with...more

Hanson Bridgett

IRS Clarifies Income Tax Withholding and Reporting Obligations for Uncashed Retirement Checks

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When an employer (or the proper withholding agent, like a plan administrator) issues a retirement benefit, there is generally an obligation to withhold income tax on the payment and to report the payment on Form 1099-R....more

Proskauer - Employee Benefits & Executive...

IRS Clarifies that Failure to Cash Checks Does Not Affect Withholding or Reporting

Revenue Ruling 2025‑15 (available here) provides guidance on withholding and reporting obligations when a plan participant or beneficiary fails to cash a distribution check and a replacement check is issued. As discussed...more

Paul Hastings LLP

REIT All About It: One Big Beautiful Bill — Tax Updates for REITs

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On July 4, 2025, President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law, following the approval of Congress. OBBBA contains the following compelling updates from a real estate investment trust (REIT)...more

Goodwin

Online Filing of Section 83(b) Elections Is Here!

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Last year, the US Internal Revenue Service (IRS) released Form 15620 for taxpayers to make elections under section 83(b) of the Internal Revenue Code, an important part of US tax planning for founders, employees, board...more

Husch Blackwell LLP

IRS Issues Guidance on Uncashed Retirement Plan Checks

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The IRS has released Revenue Ruling 2025-15, which clarifies the federal tax withholding and reporting responsibilities of retirement plan administrators when a distribution check is issued but remains uncashed and a...more

Rivkin Radler LLP

Three Big Beautiful M&A Takeaways

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It hasn’t taken long for the business world to start unpacking the implications of the newly passed One Big Beautiful Bill Act (OBBBA). While media coverage has mostly centered on its impact on individual taxpayers and the...more

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