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Article
Taxpayers Claiming QBI Deduction May Face Increased Audit Risk
Although many businesses providing services in the field of performing arts are not eligible for the qualified business income (QBI) deduction...
United StatesTax
Venable LLP
Article
Ten Minute Interview: Reducing Transaction Risk (Video)
First enacted in 1993, Qualified Small Business Stock (QSBS) has emerged as one of the most powerful wealth-building mechanisms available to founders, early employees, and venture investors. Section 1202 of the Internal Revenue Code provides substantial tax benefits, allowing up to $15 million in capital gains to be shielded from federal taxes on qualifying stock sales. With Congress expanding the exclusion in 2025, understanding the requirements and strategic implications of QSBS has become increasingly cr
United StatesTax
Foley & Lardner LLP

Tennessee Trial Court Holds That Third-Party Logistics Provider Is Not Exempt From Tennessee Business Tax

A Tennessee trial court has rejected a third-party logistics provider's challenge to a Tennessee business tax assessment.

United StatesTax

Bradley Arant Boult Cummings LLP

The American Taxpayer Relief Act - How It Applies To Businesses

A summary of some of the changes included in the new tax law that may apply to businesses, folowing President Obama signing the "American Taxpayer Relief Act of 2012" into law.

United StatesTax

The Supreme Court Takes A Deep Dive Into Potentially Perilous Water With The Moore Case

Oral argument began on Tuesday in Moore v. United States. Commentators have blogged, tweeted, and written about the potential resounding implication of a verdict in this case.

United StatesTax

Carter Ledyard & Milburn LLP

Treasury Announces Regulations To Address Use Of U.S. LLCs

In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners.

United StatesTax

Caplin & Drysdale, Chartered

Treasury Secretary Willing To Consider Regulatory Response To Inversions

Treasury Secretary Jacob Lew said last week that the Obama administration is considering administrative options to curb inversions.

United StatesTax

Grant Thornton LLP

U.S. Tax Court Rules Against Physician Group In Practice Sale

The United States Tax Court ruled recently that a group of individual physicians who sold their practice group to a nonprofit hospital were not entitled to take a charitable deduction for the value of intangible assets each individual allegedly conferred in the sale.

United StatesTax

Waller Lansden Dortch & Davis

Virtual Currency Tax Consequences

A growing number of startups are offering virtual currencies to investors through initial coin offerings (ICOs) as a way to raise capital, often with little or no awareness of the tax consequences of their actions.

United StatesTax

Wells Fargo Victory Broadens Interest Netting For Merged Corporations

The United States Court of Federal Claims recently granted partial-summary judgment to Wells Fargo & Company in a significant interest netting case.

United StatesTax

“Bellsouth Advertising v. Chumley”: Tennessee Court Of Appeals Upholds Commissioner Of Revenue’s Variance

Taxpayers filing Tennessee franchise and excise tax returns should take note of the recent Tennessee Court of Appeals ruling in "BellSouth Advertising & Publishing Corp. v. Chumley", in which the Court concluded that the Commissioner had properly exercised her power to vary the statutory apportionment formula that was based on cost of performance to impose, instead, a market-based apportionment factor.

United StatesTax

Waller Lansden Dortch & Davis

Belgian Qualified Stock Option Plans Can Be Extended By Five Years - But Only By Electing Before July 31st

Belgian corporate taxpayers that have a Regulated Stock Option Plan ("RSOP") in place that complies with the Law of March 26, 1999, can extend the exercise term of those options by up to five years without triggering additional Belgian income tax for the beneficiaries, provided appropriate action is taken before July 31, 2009.

European UnionTax

Federal Agencies Issue Guidance On Employer Trump Account Contributions

The Treasury Department and IRS have issued new guidance on employer contributions to Trump Accounts, the tax-advantaged investment accounts for children created under President Trump's One Big Beautiful Bill. Employers can now make tax-free contributions of up to $2,500 annually to these Section 530A accounts for employees or their dependents, subject to specific plan requirements and non-discrimination rules.

United StatesEmployment and HR

Hall Benefits Law

IRS To Increase Penalties For Employers’ Failure To Comply With ACA

The Internal Revenue Service has announced significant increases to Affordable Care Act penalty levels for 2027, with employers facing substantially higher costs for non-compliance with healthcare coverage requirements.

United StatesEmployment and HR

Hall Benefits Law

Cadwalader Attorneys Summarize Elements Of U.S. Tax Reform Proposals

Cadwalader attorneys summarized the business tax reform proposals from the House Republicans' "A Better Way" plan, released by House Speaker Paul Ryan...

United StatesTax

Hogan Lovells Cadwalader

California Tax Reform Should Include Ending Pay-to-Play

On August 3, 2004, the California Performance Review ("CPR") issued its long awaited report to the public. Among its many recommendations was the creation of a California Tax Commission that would consolidate the functions of California’s three taxing agencies: the Employment Development Department (payroll taxes), the Franchise Tax Board (income taxes), and the Board of Equalization (property, sales and use and miscellaneous taxes).

United StatesTax

Morrison Foerster

GILTI Until Proven Innocent: Down The Rabbit Hole Of Global Intangible Low-Taxed Income – Tax Notes International

The Tax Cuts and Jobs Act (P.L. 115-97) that President Trump signed into law on December 22, 2017, affects many areas of U.S. domestic and international tax planning.

United StatesTax

Butler Snow LLP

IRS Rules That No Part Of Cost For Wind Facilities Is Allocated To Power Purchase Agreements

The IRS has ruled in PLR 2012-14-007 that no portion of amounts paid by an electric company to acquire wind energy facilities subject to facility-specific power purchase agreements will be allocated to the agreements and that the purchase price of the facilities that can be attributed to the agreements will be used in determining the adjusted basis of the facilities.

United StatesTax

Grant Thornton LLP

Executive Compensation At Tax-Exempt Organizations Back In The Limelight – IRS Issues New Guidance

The IRS recently issued proposed regulations providing guidance under Internal Revenue Code ("Code") Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives...

United StatesCorporate/Commercial Law

Seyfarth Shaw LLP

Moving Your LLC Out of Washington: What Property Owners Should Know

Property owners considering relocating their Washington LLCs face important decisions about entity formation, real estate transfer tax exemptions, and foreign registration requirements. Understanding the legal mechanics of transferring real property to out-of-state entities while maintaining tax-exempt status requires careful coordination between legal structure and ownership percentages. The choice between statutory conversion and forming new entities carries distinct implications for compliance, privacy,

United StatesCorporate/Commercial Law

Summit Law Group

Showing 581–600 of 3726 results

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