News & Analysis as of

Taxation Settlement

Mayer Brown

Brazilian Internal Revenue Service Publishes New Rules for Low-Value Debts and Debts Up to BRL 50 Million

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On July 7, 2025, the Brazilian Internal Revenue Service (IRS) published Notices No. 4/2025 and No. 5/2025, introducing new modalities of tax settlement by adhesion within the scope of administrative tax litigation, with...more

Mayer Brown

PGDAU Notice No. 11/2025: Tax Settlement for Debt Regularization

Mayer Brown on

The Brazilian Attorney General's Office of the National Treasury (PGFN) has published PGDAU Notice No. 11/2025 (the “Notice”), which sets forth the conditions for tax settlements to regularize debts up to BRL 45 million...more

Walkers

Key considerations for trustees deciding whether to exercise their power of appointment

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Among a trustee's numerous powers, the exercise of its power of appointment is one it will most often be asked to consider exercising. It is also the power that will come under the most scrutiny from beneficiaries....more

Shook, Hardy & Bacon L.L.P.

NCAA’s $2.8 Billion Athlete Revenue Settlement Receives Final Approval

Not only does Judge Claudia Wilken’s final approval of the In re: College Athlete NIL Litigation settlement provide $2.576 billion in damages for settlement class members, it changes the rules of the game for current and...more

Stikeman Elliott LLP

Tax Court of Canada Denies GST/HST Input Tax Credit Claims in Connection with a Settlement Payment

Stikeman Elliott LLP on

In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...more

Foodman CPAs & Advisors

IRS Pilot Mediation Programs

On 1/15/25, the IRS announced three pilot programs to test changes to existing Alternative Dispute Resolution (ADR) programs. The new IRS Pilot Mediation Programs are designed to help taxpayers resolve tax disputes earlier...more

JAMS

Wage and Hour Mediations: Consider Tax Issues Beforehand

JAMS on

In employment cases, the structure of settlement payments may have significant tax consequences for clients. Often the tax consequences depend on whether the settlement payments are for loss of income damages, which are...more

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