Last week, we presented the first half of our "Top 10 Questions" regarding the pending reconciliation package. Here is the highly anticipated second half of the list.

Perhaps the most newsworthy item in the Treasury Department Greenbook was the Biden Administration's proposal to increase taxes on capital gains on a retroactive basis.

On October 5, 2023, Treasury and the IRS issued proposed regulations under section 367(b) addressing so-called "Killer B" triangular reorganizations and inbound reorganizations.

As an initial matter, these proposals purport to fully offset over $4 trillion in spending for traditional and "social" infrastructure investment.

On September 21, 2023, the U.S. Court of Appeals for the Federal Circuit clarified the boundary between the step transaction doctrine and the economic substance doctrine...

This week looks hectic as House GOP leaders and the Biden administration stare down each other over funding the government. But before we get to the Saturday shutdown deadline...

Once promulgated, the implementing regulations for the CTA could potentially affect all U.S. companies, even those that are exempt from reporting beneficial ownership information.

Last week, the General Services Administration (GSA) announced the results of the Transactional Data Reporting (TDR) pilot for FY2020. The announcement indicates that GSA remains committed to this...

Neste episódio, falamos com o ex-ministro da Justiça do Brasil Sergio Moro sobre o crescimento dos programas de compliance no Brasil e como as autoridades brasileiras avaliam os programas de compliance.

Tax policy observers will be focused on the U.S. House of Representatives this week as it returns for a rare session during the August Congressional recess to consider the Senate-passed Fiscal Year 2022 budget resolution.

On October 18, 2023, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued certain targeted relief from Venezuela-related sanctions...

The IRS today issued annual guidance that adjusts for inflation the dollar limitation amounts for 401(k) plans, pension plans and other retirement provisions for 2024.

In United States v. Barrett, the court declined to block an accountant's testimony concerning tax return preparation, holding that the attorney-client privilege and work product doctrine do not apply.

Bipartisan legislation was recently introduced in the Senate imposing significant restrictions on donor-advised funds (DAFs) and private foundations.

Among the revenue offsets contained in the Made In America Tax Plan to fund infrastructure efforts is a proposal to invest in tax enforcement against corporations

The IRS announced in interim guidance that it would amend Section 20.1.7 of the Internal Revenue Manual to provide a methodology for the calculation of intentional disregard penalties under Section 6721...

The Treasury Department released its long-awaited "General Explanations of the Administration's Fiscal Year 2022 Revenue Proposals" (the so-called "Greenbook").

The potential timing for enactment of an infrastructure package (perhaps the end of September, at the earliest) suggests that any tax increases would be effective for 2022.

As the House of Representatives and Senate focus on year-end legislative priorities, both chambers paid significant attention to the IRS last week.

Earlier this month, over 130 members of the OECD's Inclusive Framework (IF) signed on to the institution's two-Pillar framework to overhaul the international tax regime.