The compliance complexities surrounding foreign security futures continue to pose considerable challenges for global law firms and corporate lawyers. Notably, the term “security future” operates somewhat ambiguously within the US financial system, resembling the mythical creature “tragelaph” that Aristotle cited as an example of a concept possessing significance, despite its non-existence. In concrete terms, while…
As part of an extensive $1 billion tax relief package, Massachusetts has taken decisive steps to improve both affordability and competitiveness within the Commonwealth. The cornerstone of the legislation revolves around key changes in estate tax and capital gains tax rates. Under the new bill, Massachusetts legislature has decided to double the Massachusetts estate tax…
In a move stirring considerable controversy, Texas is facing backlash for its decision to apply the state’s sales tax on data processing to commissions charged by online marketplaces. Regulators, corporate legal professionals, and industry watchers alike are closely monitoring the situation. The policy, implemented by the Texas Comptroller, has met with strong disapproval, leading to…
In a notable shift towards more tax-friendly policies, Massachusetts has increased its estate tax exemption from $1 million to $2 million. This law affects estates of individuals passing on or after January 1, 2023, and was signed into effect by Governor Maura Healey on October 4, 2023. The amendment spells several implications for estate planning…
The topic at hand warrants particular consideration as it hangs over countless legal and corporate professionals: Are partner retirement or withdrawal provisions in a firm’s governing body subject to Section 409A of the Internal Revenue Code? The subject relates to broader, profound conversations in today’s corporate world about retirement or deferred compensation arrangements, and how…
In recent years, Jersey has gained an elevated status in the business and legal world with its unique legislative framework surrounding cell companies. Defined under the Companies (Jersey) Law 1991, or as it is colloquially known, the “Law”, cell companies are designed to function in a way that allows its assets and liabilities to be…
In August 2022, the Inflation Reduction Act (IRA) transferred billions of dollars in supplementary funding to the Internal Revenue Service (IRS). The move was significant as it signaled a new era in the IRAs enforcement and compliance strategy. According to a report by ArentFox Schiff, the IRS is set to utilize a portion of the…
On October 4, 2023, Massachusetts Governor Maura Healey signed House Bill 4104 into law implementing major changes in corporate taxation. The most significant modification is the adoption of the single-sales-factor (SSF) apportionment system for all corporate taxpayers. This deviation from the prior system of multi-factor apportionment, where a company’s tax rate was based on a…
On July 3, 2023, New Jersey’s Governor, Phil Murphy, signed into law A.B. 5323, an important piece of legislation presenting key revisions to New Jersey’s Corporation Business Tax (CBT). One significant change includes an expansion to the definition of what is considered a “unitary business.” According to Pillsbury’s SeeSalt Blog, the revised definition now encapsulates…
Major legal and financial shifts in large partnership tax enforcement are occurring. With the IRS’s Large Partnership Compliance program launched in 2021, along with its recent commitment to establish a group devoted to large partnership audits next year, increased attention is being paid to passthrough entities. Large partnerships are no longer able to fly under…
On September 29, 2023, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) released the 2023–2024 Priority Guidance Plan. Highlighting not only areas of tax law and administration that have been identified for further investigation, but also demonstrates an acute awareness of the ongoing global shift towards renewable energy. The Priority Guidance…
In an effort to modernize Massachusetts’ outdated estate tax laws, historic tax relief legislation has been enacted by the state. On October 4, 2023, Massachusetts Governor Maura Healey signed the comprehensive tax package, known as “An Act to improve the Commonwealth’s competitiveness, affordability, and equity.”JD Supra reported. The tax reform is expected to bring widespread…
Washington state residents have recently challenged the state’s efforts to tax long-term capital gains, in an intriguing legal showdown that pivots around the state and federal constitutional considerations. The dispute, teetering on the edge of constitutional and tax law, emerged from a legislative measure passed by Washington’s Democratic-controlled legislature in 2021. The enactment proposed a…
In a landmark move on October 4, 2023, Massachusetts Governor Maura Healey (D) put pen to paper, signing House Bill 4104 into law, thus repositioning Massachusetts towards a single sales factor apportionment regime for multi-state business corporations and financial institutions. Read all about this new development here. This legislation signals a shift in the way…
The week of September 21 – September 27, 2023, has seen notable activities and publications from the Internal Revenue Service (IRS). From issuing critical guidelines to various other tax matters, the IRS has remained highly active. A summary provided by McDermott Will & Emery provides an extensive overview of IRS’ operations and actions throughout this…
As the November 2023 election draws near, major tax topics, especially pertaining to property tax measures, take center stage in Colorado, promising yet another intense round of voter decisions. Indeed, these decisions are likely to have significant implications for both individuals and businesses within the state. The tax measures put forth, will, according to indications…
A buzz of anticipation has settled over the world following the recent implementation of a new multilateral tax treaty, which applies the Subject to Tax Rule and affects more than 135 jurisdictions. Since October 2021, numerous jurisdictions, spanning across multiple continents, have joined in an innovative plan to tackle specific tax challenges that are emerging…
In an ambitious move to improve the state’s competitiveness, affordability, and equity, Massachusetts has enacted a new law that could potentially change the financial dynamics for many of its taxpayers. Known as “An Act to improve the Commonwealth’s competitiveness, affordability, and equity,” the legal development was set in motion on October 4, 2023, and incorporates…
On October 4, 2023, Massachusetts’s Governor Healey put pen to paper, signing into law a key piece of tax legislation. The reform introduces a multitude of changes, offering relief measures such as estate tax reductions, sealing a loophole around the recently established millionaire’s tax, as well as slicing short-term capital gains tax rates. This large-scale…
In a notable development, the Massachusetts Senate has approved Bill H. 4104 aimed at elevating the Massachusetts estate tax filing threshold to $2,000,000. This pivotal decision came to light on Thursday, September 28, 2023, just a day after the Massachusetts House of Representatives also shared its endorsement for the bill on Wednesday, September 27, 2023….
As legal professionals engaged in global corporations and law firms, your awareness of international tax developments is critical. It’s important that we examine an issue recently gaining momentum and largely impacting the tax world: The IRS’s crackdown on perceived ‘abusive trust arrangements’. To provide some widespread perspective, recent government actions hint that both third-party promoters…
As the landscape for the cannabis industry in New York changes, businesses are being presented with new opportunities. Beginning October 4, the state has started accepting applications for certain adult-use cannabis licenses, marking a key moment in the establishment of the state’s legal cannabis market. According to JD Supra, the available licenses include cultivator, processor,…
In an unexpected turn of events, the Federal Trade Commission (FTC) has recently flagged what can be classified as a novel form of unsportsmanlike conduct. According to a notice it sent to five tax preparers, the commission expressed its intent to pursue civil penalties if these entities continue to utilize consumers’ data for motives beyond…
In a turning point for the U.S. cannabis industry, the Department of Health and Human Services (HHS) has issued a recommendation to reschedule marijuana to Schedule III under the Controlled Substances Act of 1970 (CSA). Historically, marijuana has been classified as a Schedule I controlled substance – a category defined as a substance with no…
Since taking office in 2021, the Prime Minister of Japan, Kishida Fumio, has been known for his quest to pioneer “a new form of capitalism”. A significant part of his vision is rooted in the creation and implementation of a “national strategy” aimed at the expansion of Japan’s digital economy in the age of Web…