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Holland & Knight
Gov. Bill Lee recently signed into law Public Chapter 950, which creates significant changes in how Tennessee's franchise tax is calculated.
Holland & Knight
The IRS on May 16, 2024, released Notice 2024-41, which modifies the existing domestic content safe harbor in Notice 2023-38. Importantly, Notice 2024-41...
Holland & Knight
The Liberty Global Inc. v. United States appeal has practitioners and taxpayers concerned that the economic substance doctrine will be applied to disallow the tax benefits of ordinary course of business...
Buckingham, Doolittle & Burroughs
The costs associated with hiring attorneys, defending a lawsuit, and paying for damages or a settlement can be exorbitant, and will inevitably damage a company's profitability.
Alvarez & Marsal
Virginia has long-standing research and development (R&D) tax credits in place aimed at incentivizing innovation within the state. The credits are provided to businesses and individuals engaged...
Caplin & Drysdale
What are current trends in US tax disputes? How can you reduce litigation risk? What is the Supreme Court likely to make of Moore, a case that could call into question large swathes of the US tax system?
Katten Muchin Rosenman LLP
It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign...
Taft Stettinius & Hollister
On May 10, 2024, the IRS released Rev. Proc. 2024-25, which increases the contribution limit for Health Savings Accounts (HSA), the minimum deductible and maximum...
Ankura Consulting Group LLC
In this article, we delve into the intricacies of valuing individual legal entities as part of a legal entity rationalization, exploring some of the key considerations that must be considered to prepare a robust...
Holland & Knight
The USTC has affirmed it will adhere to its decision that the IRS lacks authority to assess Section 6038(b) penalties in cases falling under other circuits of the U.S. Courts of Appeals.
Greenberg Traurig, LLP
On April 12, 2024, as required under I.R.C. § 7431, the Internal Revenue Service notified over 70,000 taxpayers that their tax return information was subject to a data breach perpetrated by an IRS...
Kelley Drye & Warren LLP
As noted in our prior advisory, U.S. citizens and residents who receive gifts exceeding certain thresholds from foreign persons must generally report such gifts to the IRS on Form 3520...
KI Legal
When starting a new business, or considering restructuring an existing one, one of the most critical decisions you will face is choosing the right entity type.
Alvarez & Marsal
On the same day many company installments were due, the IRS and Treasury granted limited penalty relief for underpaying estimated tax installments based on the corporate alternative minimum tax.
Alvarez & Marsal
It's increasingly evident that companies are seeking to design supply chains and operating models that are flexible, resilient and can improve tax efficiency.
Jones Day
In October 2020, the Organization for Economic Co-operation and Development Secretariat released a report addressing its "Pillar Two" blueprint for an overhaul of the international tax system.
Greenberg Traurig, LLP
In this episode of GeTtin' SALTy, host Nikki Dobay is joined by Brad Scott, director of finance at Halstead Beads, to discuss where sales tax collection requirements are at six years after the landmark Wayfair decision.
Jones Day
The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs.
Holland & Knight
The IRS recently issued a private letter ruling (PLR) that a utility's net operating loss carryforward (NOLC) cannot be reduced by tax allocation payments under the normalization rules.
Greenberg Glusker Fields Claman & Machtinger
The United Nations has offered a framework for countries that want to consider a wealth tax. For advisers of ultra-high net worth clientele in the US...
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