On November 1, 2023, the U.S. Internal Revenue Service (IRS) released a critical notice on the financial landscape for legal professionals, particularly those specialising in taxation and corporate finance. Notice 2023-75 detailed the cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans for the year 2024. The IRS also shared significant…
In a significant move for the cannabis industry in New York City, Governor Kathy Hochul signed a bill on November 20, 2023, that permits deduction of business expenses incurred by cannabis businesses with respect to their city income tax liabilities. The bill can be seen as another step towards normalizing the cannabis industry within the…
In the wake of COVID-19’s impact on the workforce, New York’s “Convenience of the Employer” rule has become one of the significant state and local tax issues. Regular readers will be well aware of this. For those less familiar, this rule stipulates that nonresident employees’ wages earned while working out of state for a New…
The most recent filing in the significant tax case, Moore v. United States, has presented compelling arguments for the US Supreme Court to invalidate the mandatory repatriation tax. This outcome, according to observers, could potentially lead to billions in tax refunds for US multinationals. Taxpayers Charles and Kathleen Moore have clarified their standpoint in their…
The Internal Revenue Service has recently announced a potentially significant change that would affect large corporations and individuals alike. The annual gift exclusion – the maximum amount one can gift to an individual within a year free of tax implications – is set to see a considerable rise in 2024. JD Supra reports that the…
In 2018, voters in San Francisco approved the introduction of the Early Care and Education Commercial Rents Tax (“Commercial Rents Tax”). Implemented as of January 1, 2019, this tax generally levies a 3.5% surtax on revenue a business collects from the lease or sublease of commercial spaces in the city, plus a 1% surtax on…
On November 7, 2023, Ohio welcomed a historic transformation in its jurisdiction. This change arrived in the form of Issue 2, a well-received measure signaling a clear shift in Ohio’s stance towards marijuana. With the passing of Issue 2, Ohio joyously entered the record books as the 24th U.S. state to decriminalize adult-use marijuana. This…
Divorce procedures present numerous complexities, not the least of which is how to manage various financial accounts. Recently, there has been extensive discourse surrounding the question of whether, when, and how individuals with conventional IRA accounts should evaluate potentially converting them to Roth accounts. This aspect significantly impacts the legal professionals who are guiding their…
The U.S. Internal Revenue Service (IRS) recently unveiled a new set of compliance guidelines focused on the enhanced scrutiny of high-income/high-net-worth individuals, companies, corporations and promoters who exploit existing tax regulations. As cited in a recent article by Foodman CPAs & Advisors, these efforts aim to leverage advanced technologies, notably artificial intelligence, to pinpoint sophisticated…
In a significant development for American taxpayers, recent reports suggest that the Internal Revenue Service (IRS) may decide to leave more in the workers’ paychecks in 2024, a move that is bound to create ripples throughout the professional and business communities as detailed by Allen Barron, Inc. Understanding the potential implications requires a deeper dive…
Gift and estate taxation is a topic of great importance, as the tax code’s outlined requirements can significantly impact an individual’s financial planning. Understanding and effectively navigating these requirements are both essential. The tax laws encompass gift and estate tax concepts, implications on individuals, and answers to common questions. This article aims to provide clarity…
Since its inception in 2006, the IRS Whistleblower Program has facilitated the recovery of over $6.6 billion from wealthy tax defaulters and non-compliant corporations. This effort has resulted in rewards amounting to $1.1 billion being paid to over 2,500 whistleblowers. However, in recent times, the program has grappled with delayed award claims and a climactic…
As the year draws to a close, many are revisiting the tax implications of noncash charitable donations, particularly the increasingly prevalent digital assets. This informative piece elaborates on the subject, offering key insights. The valuation of noncash items donated to charity is a complex process, with tax rules stipulating various tiers of deductions dependent on…
On October 16, 2023, the Council of Ministers in Italy approved a preliminary examination of the draft for a legislative decree concerning tax reforms on international taxation. This news was first reported by law firm McDermott Will & Emery. This proposed decree is particularly relevant to legal professionals working in multinational corporations and international law…
In a recent ruling, the Missouri Public Service Commission (MPSC) underscored the concept that a tax expense is a theoretical construct, calculated by multiplying the rate base by the rate of return and by the statutory tax rate. This decision was made in relation to an ongoing issue with a regulated public utility in Missouri…
On November 1, 2023, the Canada Revenue Agency (CRA) released a catalog of transactions that have been classified as the inaugural “notifiable transactions” under the recent Mandatory Disclosure Rules (MD Rules) in the Income Tax Act (Canada) (ITA). These rules were officially enacted on June 22, 2023. (JD Supra). The system of “notifiable transactions” is…
Recent memory serves to remind us all of the astronomical, record-setting $2.04 billion Powerball lottery win that took place a year ago today. Even more incredible is the fact that this was a close second to the breathtaking $1.765 billion jackpot claimed just last month in October 2023. With windfalls of this magnitude, one cannot…
In the context of corporate sales, Pillar Two could significantly impact tax risk apportionment. With the commencement of Pillar Two at the end of 2023, drafting a tax covenant when the Seller Group is within its scope is becoming a prevalent issue for legal professionals. Pillar Two represents a global initiative to ensure multinational enterprises…
The process of approving the U.S.-Chile bilateral income tax treaty (the Tax Treaty) continues in earnest. On October 25, the Chilean government submitted the reservations made by the United States Senate to the Chilean Congress for approval. Chilean tax practitioners anticipate the approval process of the Tax Treaty to conclude either this year or in…
On August 4, 2023, the Canadian Department of Finance issued a revised version of the proposed 2% equity buyback tax, colloquially known as the “Buyback Tax”. This taxation measure is intended to be applied to related transactions taking place on or after the beginning of 2024. As part of the government’s ongoing commitment to ensuring…
Often, individuals and corporations are perplexed by the complexities of tax audits, particularly those conducted by the Internal Revenue Service (IRS) and the state of California. A key aspect that often raises questions is the “statute of limitations”, the prescribed time within which the IRS or California must complete an audit of tax returns. The…
As 2024 approaches, sharp eyes are on the landscape of international cannabis reform. Born out of a blend of societal shifts, economic considerations, and evolving perspectives on health and welfare, many countries are moving towards more liberal cannabis policies. This, in turn, will influence international relations, trade, and legal considerations of multinational corporations and global…
Corporate functions such as entity management and matter management can present complex, time-consuming challenges. For those looking to modernize and automate these tasks, the options largely involve relying upon disjointed point solutions, which often translate to disparate systems that lack a unified approach. From this perspective, today’s launch of Traact, a SaaS platform developed by…
In recent years, legal and fiscal strategies employed in the realm of divestiture transactions have been a subject of deep analysis. Recently, a district court ruled on the legitimacy of employing dividend distribution prior to a share sale to potentially mitigate tax liabilities. This strategy manifests itself through the selling shareholders distributing dividends before the…
The ongoing income tax dispute PepsiCo Inc. v. Illinois Dept. of Revenue is shedding light on a state tax provision that encourages profit shifting by multi-jurisdictional taxpayers. This provision involves the exclusion of 80/20 companies from the combined filing requirements of nearly 15 states. An 80/20 company is a domestic corporation, subject to federal tax,…