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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...
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...
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...
McLane Middleton, Professional Association
Q: With the 2020 election quickly approaching, I have seen various articles and commentary on people wanting to make gifts or engage in estate tax planning before the end of the year.
Morrison & Foerster LLP
A long-running High Court battle over legal privilege in regulatory audit investigations ends in success for the Financial Reporting Council and provides further clarity on the application ...
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
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 ...
Proskauer Rose LLP
Important federal interest rates continue to hold relatively steady. The October Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 0.4%, which is...
Ropes & Gray LLP
The IRS has been closely scrutinizing syndicated conservation easements since December 2017.
Duane Morris LLP
The Internal Revenue Service has instituted a new program aimed at examining the failure to file somewhat esoteric information-reporting tax forms related ...
Vistra
What PE Is, How It's Changing and How to Protect Your Organization.
Vistra
Multinational organisations have been operating during a pandemic for six months now. Over that span many employers have increasingly ...
Caplin & Drysdale
Taxpayers with cost sharing arrangements ("CSAs") can again expect close audit scrutiny—and potential adjustments—related to their treatment of stock-based compensation ("SBC") costs.
Mayer Brown
Bylined article by Tax Transactions & Consulting partners Zal Kumar and Leah Robinson; as well as Litigation & Dispute Resolution partner Daniel Stein (all New York).
Duane Morris LLP
On August 28, the IRS announced that it would temporarily allow the use of digital signatures on certain forms that cannot be filed electronically.
Vistra
Vistra's latest survey of 620 corporate services executives suggests some are expecting international alignment on tax, transparency and substance regulations to wane in the year ahead.
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