Maryland's Sales Tax on IT and Data Services
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5 Key Takeaways | Artificial Intelligence: What Tax Professionals Need to Know
Avoiding Tax Consequences During Oil & Gas Restructurings
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
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
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
What's this all about? Employee participation programs – whether equity-based (ESOPs) or virtual (VSOPs) – are a standard feature for German start-ups. They’re designed to incentivize and retain talent, and they play a...more
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
Often in healthcare transactions, retaining a federal Employer Identification Number (“EIN”) after an acquisition or restructuring is essential to the continuity of operations, regulatory compliance, and preservation of key...more
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
Given the recent amendments to Internal Revenue Code Section 1202,1 which increase the benefits of holding qualified small business stock (QSBS), many companies currently operating as tax partnerships may want to convert into...more
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
A recent decision from the Ontario Court of Appeal is a good reminder that courts won’t bail you out just because a tax plan didn’t go as expected. In Pyxis Real Estate Equities Inc. v. Canada, 2025 ONCA 65, the Court made it...more
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
Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more
On July 25, 2025, the IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (Control Number: LB&I-04-0725-0008) implementing changes for LB&I audit procedures, which take effect August 1,...more
Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more
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
On July 23, 2025, the French Tax Administration released its initial draft guidance in the BOFiP (Bulletin Officiel des Finances Publiques) (the “Tax Comments”) on the new tax regime for Management Packages introduced by the...more
Key Takeaways: - On July 4, 2025, “The One Big Beautiful Bill Act” (the “Act”) was signed into law, introducing significant expansions of the tax benefits of “qualified small business stock” (“QSBS”) issued on or after July...more
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
In late 2024, the Internal Revenue Service (IRS) introduced Form 15620 to provide a standardized mechanism for taxpayers to make elections under Section 83(b) of the Internal Revenue Code (the “Code”). More recently in 2025,...more
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
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
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
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
On Friday, July 4, 2025, President Trump signed into law the Reconciliation Bill commonly known as the One Big Beautiful Bill Act (OBBBA). Broadly speaking, the OBBBA extends and makes permanent many provisions enacted by the...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. Among the many changes, the Act expands the favorable tax treatment for Qualified Small Business Stock (“QSBS”) under Section 1202...more