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Venable LLP
Although many businesses providing services in the field of performing arts are not eligible for the qualified business income (QBI) deduction...
Withers LLP
With the impact of rampant U.S. federal government stimulus spending to address the coronavirus pandemic and the continuing impact of tax cuts under the 2017 Tax Cuts and Jobs Act (TCJA), the...
Shearman & Sterling LLP
Significant tax reform could be imminent, depending on whether Biden or Trump wins next month's election and which party controls Congress.
Shearman & Sterling LLP
On October 13, 2020, the U.S. Department of Treasury ("Treasury") and the Internal Revenue Service (the IRS) released final regulations (T.D. 9927) (the "Regulations") under sections 1502 and 1503...
Arnold & Porter
In the waning days of the COVID summer, the District of Columbia (DC or District) eliminated a valuable tax exemption that real estate investors have routinely used to avoid paying DC taxes on the ...
Proskauer Rose LLP
On October 7, 2020, the U.S. Internal Revenue Service and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests by non-U.S. persons.
Sheppard Mullin Richter & Hampton
As reported in our earlier blog post The CARES ACT – Tax Relief, the federal CARES Act provides for forgiveness of indebtedness for eligible recipients of Paycheck Protection Program ("PPP")...
Smith Gambrell & Russell LLP
Well, not quite yet. But it's not too soon to start thinking about gifts, particularly gifts which use your lifetime exemption.
Shearman & Sterling LLP
On October 7, 2020, the U.S. Department of Treasury ("Treasury") and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the "Final Regulations") with respect to the ...
Vistra
Chilean tax authorities recently adopted a three-tiered approach to transfer pricing documentation. Chile is one of the few Latin American countries...
Holland & Knight
The IRS Large Business & International Division (LB&I) announced on Oct. 5, 2020, the latest IRS audit campaign targeting nonresident aliens (NRA)
WilmerHale
In the recent decision of The Financial Reporting Council Limited v Frasers Group Plc, the English High Court held that documents detailing advice received from accountants
Ropes & Gray LLP
THIS HAS BEEN AN UNUSUAL YEAR, by any measure, and it is not over yet. As we head into the last quarter of 2020, there are some personal planning possibilities to consider.
Ruchelman PLLC
Earlier this year, the I.R.S. updated its Transfer Pricing Documentation Best Practices F.A.Q. list with a response to Q. 4, What are some areas the I.R.S. has identified in transfer pricing...
Ruchelman PLLC
Today's cross border tax planners are expected to know all there is about various provisions of Subchapter N of the Internal Revenue Code.
Ruchelman PLLC
The I.R.S. recently released drafts of two new partnership return schedules and accompanying instructions to replace, supplement, and clarify the way partnership income, loss, deductions, credits and other items ...
Ruchelman PLLC
In the Tax Cuts and Jobs Act of 2017, Pub. L. No. 115-97, the U.S. Con¬gress enacted the most dramatic change to the U.S. Tax Code since 1986, adding among other provisions G.I.L.T.I.'s quasi-territorial tax under Code §951A.
Ogletree, Deakins, Nash, Smoak & Stewart
In this episode of the Global Solutions series, Jean Kim and Mike Mahoney discuss the tax implications that emerge when expatriates work remotely outside of the United States...
Ostrow Reisin Berk & Abrams
With the presidential election only weeks away, many people are beginning to pay closer attention to each candidate's positions on such issues as the COVID-19 pandemic, health care...
Ropes & Gray LLP
The IRS has been closely scrutinizing syndicated conservation easements since December 2017.
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