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Trump Administration Tax Liability Tax Reform

Butler Snow LLP

The One Big Beautiful Bill Act and Its Potential Business Impact

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “OBBB”) into law. While technically a budget reconciliation law, the OBBB is a significant piece of legislation that prioritizes this...more

Haynes Boone

Federal Estate, Gift and GST Tax Highlights from the One Big Beautiful Bill Act

Haynes Boone on

The recently enacted One Big Beautiful Bill Act (OBBBA) brings sweeping and permanent changes to the federal estate, gift and generation-skipping transfer (GST) tax landscape. Most notably, it significantly increases the...more

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Amendments to the Excise Tax Imposed on Certain Private College and University...

Troutman Pepper Locke on

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). This legislation includes significant amendments to the excise tax imposed on...more

Husch Blackwell LLP

Understanding the OBBBA’s FEOC Framework

Husch Blackwell LLP on

The One Big Beautiful Bill Act (OBBBA), signed into law by President Donald Trump on July 4, 2025, provides for enhanced restrictions on entities claiming many of the renewable energy credits established under the Inflation...more

Bilzin Sumberg

Key Tax Provisions in the One Big Beautiful Bill Act: What Individuals and Businesses Need to Know

Bilzin Sumberg on

The enactment of the One Big Beautiful Bill Act (“OBBBA”) on July 4, 2025 is the first key piece of tax legislation passed during President Trump’s second administration. While preserving much of the structure established...more

Cole Schotz

Salt Provisions In The One Big Beautiful Bill Act: A Mirage Rather Than A Panacea Of Relief For High-Income Earners

Cole Schotz on

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law ushering in sweeping federal tax changes. The legislation notably expands the Qualified Business Income (QBI) deduction for professionals...more

Warner Norcross + Judd

One Big Beautiful Bill Enacts Important Health and Welfare Plan Updates

Warner Norcross + Judd on

On July 4, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBB), a sweeping piece of legislation that includes several provisions impacting employer-sponsored health and welfare benefit plans. The OBBB...more

Amundsen Davis LLC

No Tax on Tips—But What About Overtime and Social Security?

Amundsen Davis LLC on

Earlier this year, many low-income taxpayers were elated to learn about the possibility that tipped wages could receive federal income tax relief under the No Tax On Tips Act. Under President Trump’s “One, Big Beautiful...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

Troutman Pepper Locke on

On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

Troutman Pepper Locke on

Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more

Ankura

Navigating Change: How 2025 Tax Changes Could Affect M&A Dynamics

Ankura on

In the merger and acquisition (M&A) landscape, it is crucial to consider factors beyond the transaction itself, as the 2025 calendar year is already underway. Evaluating how potential 2025 tax changes and any changes beyond...more

Cadwalader, Wickersham & Taft LLP

DeFi Off the Hook for Crypto Tax Reporting

Congress and President Trump have provided legislative relief to decentralized crypto exchanges (and DeFi protocols) from the tax reporting obligations applicable more generally to crypto ‘brokers.’ On April 10, President...more

Husch Blackwell LLP

Impending IRS Workforce Cuts Mean Taxpayers Should Act Now to Resolve IRS Issues

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The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more

Fox Rothschild LLP

Trump May Revive Effort to Close Carried Interest Loophole

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President Trump is meeting with Republican lawmakers to discuss potential tax code changes, including a proposal to eliminate the carried interest tax break. White House Press Secretary Karoline Leavitt announced the...more

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Proskauer - Tax Talks

Trump Administration Disavows the OECD Global Tax Deal

Proskauer - Tax Talks on

On January 20, 2025, the White House issued a memorandum (the “Memorandum”), announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect...more

Proskauer - Not for Profit/Exempt...

Repeal of Unrelated Business Income Tax on Qualified Transportation Fringe Benefits

Late on Friday, December 20, 2019, President Trump signed into law government funding legislation for the 2020 fiscal year that includes a provision repealing Section 512(a)(7), commonly referred to as the “parking tax.”...more

Mitchell, Williams, Selig, Gates & Woodyard,...

IRS Says Not So Fast to States' Attempts to Convert High State and Local Tax Obligations to Charitable Deductions to Escape TCJA...

In Notice 2018-54, the IRS has notified taxpayers that proposed regulations are forthcoming which will deny state attempts to convert a taxpayer’s state and local tax obligations to a charitable deduction in order to avoid...more

McDermott Will & Schulte

Illinois Confirms Treatment of Deemed Repatriated Foreign Earnings Provisions

On Wednesday, the Illinois Department of Revenue (Department) issued additional guidance concerning its treatment of the new deemed repatriated foreign earnings provisions found in Internal Revenue Code Section 965, enacted...more

Troutman Pepper Locke

Foreign Partners Victims of Tax Reform - Tax Update, Volume 2018, Issue 1

Troutman Pepper Locke on

More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more

Snell & Wilmer

New Tax Act: 2017 Trap for 10% U.S. Owners of Foreign Corporations

Snell & Wilmer on

The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VII: Family Matters and Major Events in the Lives of Individuals

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The Tax Cuts and Jobs Act (“TCJA”) creates the need for tax planning with respect to several major life-changing activities individuals may encounter, including marriage, divorce, home ownership, casualty losses, medical...more

Foodman CPAs & Advisors

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more

Foodman CPAs & Advisors

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more

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