Anita Siegel and Randi Siegel Weniger have joined Bressler, Amery & Ross, P.C. as principals in the trusts and estate practice at the firm’s Florham Park, NJ, office. This move comes as part of the firm’s broader strategy to enhance its expertise in taxation and estate planning. Siegel brings a focus on taxation, estate planning,…
Last week, the Supreme Court issued its much-anticipated opinion on Moore v. United States, a decision that could have led to significant changes in tax law and provided insight into whether a wealth tax could survive judicial scrutiny. In Moore, the taxpayers were shareholders in a foreign corporation since 2005. Despite the corporation’s annual profits,…
The United States Supreme Court has opted not to preemptively invalidate a potential wealth tax, choosing instead to reserve judgment until such a law is enacted and challenged. This decision comes amidst growing discussions around wealth taxation as a means to address economic inequality and fund expansive government programs. The court’s stance reflects a common…
In a recent pivotal decision, the US Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT) in Moore v. United States, affirming Congress’s capacity to tax the undistributed income of non-US entities owned by US taxpayers. The 7-2 decision, detailed in a Bloomberg report, reassures the tax community that foundational tax frameworks, including…
Tax attorneys and constitutional scholars alike are likely to debate the implications of Justice Brett Kavanaugh’s opinion in Moore v. United States for years to come. The ruling from the United States Supreme Court primarily addresses the taxation of shareholders on the undistributed income of an entity when the entity itself has not been taxed…
Ryan Leichsenring has joined Day Pitney as a tax partner in their Hartford, Connecticut office, the firm announced Tuesday. Leichsenring’s practice focuses extensively on advising tax-exempt organizations on both federal and state tax law matters. His areas of expertise include corporate structuring and formation, board governance, charitable asset management, information reporting, and unrelated business taxable…
Article As Congress confronts the impending expiration of the 2017 Tax Cuts and Jobs Act (TCJA) in 2026, the debate over how to manage the associated fiscal implications is heating up. Most individual income tax provisions of the TCJA are set to expire, and extending them would significantly increase the federal budget deficit. A potential…
In a manifestation of civic discontent, Nairobi’s streets became a battleground as hundreds of Kenyans protested against the government’s contentious Finance Bill. Demonstrators flocked to the Central Business District (CBD) on Tuesday, voicing their opposition to a bill that proposes, among other measures, the taxation of cancer treatment, sanitary pads, and diapers. The Finance Bill…
Dan Jacobs, the chef-owner of two Milwaukee restaurants, began implementing a service charge model during the COVID-19 pandemic to enhance the wages of his almost 60 employees, who were experiencing a decrease in tips. However, this decision came with a significant fiscal repercussion: a $70,000 tax bill. Jacobs’ situation underscores a contentious issue faced by…
In a moment of intensified national division, more than 110 law and undergraduate students from over 70 universities across the United States gathered in Phoenix, Arizona for the inaugural student-led US Model Constitutional Convention. Hosted by the Center for Constitutional Design at the Arizona State University Sandra Day O’Connor College of Law, this event gathers…
The question of how different countries will interpret and implement the recently agreed-upon Pillar Two global minimum tax framework has been one the largest uncertainties. This 15% minimum tax on multinational corporations necessitates that each country, with its distinct tax rules and regulatory frameworks, fall in line. The United States, in particular, must make critical…
The global minimum tax plan known as Pillar Two is already a recognized law across several countries. As tax professionals strive to assemble the complicated puzzle of effective 2024 tax rate computations, there is a noticeable mismatch. This anomaly is the Global Intangible Low-Taxed Income (GILTI), a classification of income used by the IRS to…
In an effort to delay paying the recently imposed 15% global minimum tax, US multinational corporations are reported to be engaging in deconsolidation of their foreign holding companies and subsequent reshoring of their overseas subsidiaries. According to Bloomberg Tax, this strategic maneuver may potentially stall tax payments indefinitely. This reshoring process results in a one-year…
International law firm Bryan Cave Leighton Paisner LLP (BCLP) has initiated legal proceedings against the city of St. Louis, Missouri. The law firm alleges that the municipality has unlawfully been taxing partners of BCLP who are not residents of St. Louis city. This dispute arises in the wake of St. Louis’s claims that BCLP has…
Many entrepreneurs who dream of access to the US market often overlook the critical importance of comprehensive tax planning, leading to significant issues that might jeopardize both their personal finances and their business outlook. Failure to effectively navigate through corporate and individual tax issues can potentially lead to considerable losses and thwart a successful US…
Democrats, with Senators Elizabeth Warren and Ron Wyden leading the charge, are amplifying their tax-the-rich agenda, including proposals targeting the use of trusts. President Joe Biden’s budget also suggests various means to curtail the use of trusts. However, it is uncertain whether such laws will be enacted in the near term, leaving high-wealth Americans, as…
Partnerships and S corporations are now subject to new regulations when transferring certain clean energy tax credits under Section 6418 of the tax code. Nevertheless, these entities remain advantageous for effective tax-planning, especially in regards to buying and selling energy tax credits. These entities offer clear tax benefits primarily for clean energy projects and energy…
The Department of Justice’s April 22 appeal of a case involving foreign tax credits may prove to be influential for US expats. Assuming the appeal is denied, the court’s decision could translate into noteworthy refunds for many US taxpayers residing overseas. In 2023, the US Court of Federal Claims ruled that the IRS incorrectly denied…
The recent recommendation by the Drug Enforcement Administration (DEA) to reschedule cannabis has been a topic of considerable interest among legal professionals. According to Rachel Wright and Simon Menkes of ABFinWright, while this move could potentially decrease the tax burden for businesses within the industry, changes may not be immediate. Here can be found the…
The Manhattan District Attorney’s office has subtly treaded into the realm of state taxation by indicting former President Donald Trump. The indictment inadvertently places Trump on the precipice of possibly becoming a statutory resident of New York, following allegations of falsifying business records. New York classifies individuals as residents for tax purposes if they spend…
Clifford Chance announced this week that Todd Lowther has joined the firm as a partner in the tax practice of its Houston office, thereby expanding their tax practice team. This addition increases the capability and depth of the firm’s energy sector taxation specialization, mirroring the requirement of its expansive and diverse clientele. Tax operations, especially…
The IRS recently unveiled a draft for the first crypto tax reporting form, 1099-DA, following months of collecting input on proposed regulations that would require crypto “brokers” to report customer sales and digital asset exchanges. Scheduled to be implemented in 2025, the form is a signal that finalization of crypto tax regulations is imminent. These…
In a significant development in the legal and corporate world, former general counsel of Moody’s Corp., John Goggins, has pleaded guilty to charges of not filing his tax returns for four consecutive years. Goggins was arraigned in a federal court in New Jersey last Thursday, where he admitted failing to file his tax returns from…
In a recent decision concerning New York’s tax treatment of overseas royalties, the U.S. Supreme Court is presented with the opportunity to hear another state tax case pertaining to the dormant commerce clause’s breadth. The New York State Court of Appeals decided on April 23 that both Walt Disney Co. and IBM Corp. are unable…
The uncertain future of major elements of the Tax Cuts and Jobs Act of 2017 (TCJA), set to lapse at the end of 2025, is fueling confusion and making advising clients an increasing conundrum for tax professionals. As the TCJA pertains, the absence of clarity about the fate of more than 20 temporary provisions complicates…