After months of negotiations and consideration of alternative proposals, the House Democrats advanced the Build Back Better Act reconciliation bill (the House Bill) on Friday. Now, the House Bill heads to the Senate where the Senate Parliamentarian…

With all eyes watching the Build Back Better Act make its way through Congress, much of the attention has been on the proposed domestic and international corporate tax provisions which, if enacted, would have far-reaching implications. But among the…

A landmark approach to global tax reform addressing the challenges presented by the digital economy advanced this month with 136 countries agreeing to an October 8th “Statement,” which was quickly given an endorsement by the G20 Finance Ministers.…

In a recent landmark income tax ruling, the Supreme Court of India (“Indian SC”) has delivered a notable victory to nonresident technology companies licensing software into India. In Engineering Analysis Centre of Excellence Private Limited v. CIT,…

On Friday, Senate Finance Committee Chairman Wyden released a discussion draft of potential changes to partnership tax law intended to reduce taxpayer flexibility, simplify Internal Revenue Service enforcement of partnership tax law, and increase…

Article featured on Thomson Reuters’ Taxnet Pro, August 2021.  If the past 30 days have taught us anything, it is that Yogi Berra was right when he said, “It ain’t over till it’s over.” The fourth quarter of 2021 will keep taxpayers on the…

While companies should always ensure that their executive compensation programs are aligned with their market for talent, the time leading up to and after an initial public offering (“IPO”) can often be a significant challenge for companies trying…

As discussed in our prior alert, the Treasury Department last Friday released its general explanation of tax proposals included in President Biden’s fiscal year 2022 budget submission to Congress (the “Green Book”). In this alert, we focus on some…

  Click here to download the full article. Change in control (“CIC”) arrangements have become an effective way to attract qualified candidates and to reward top performers for their success. CIC…

For many years, the Cayman Islands, Guernsey, and Jersey have been the jurisdictions of choice for U.S. investment fund managers organizing feeder vehicles or investment funds for making offshore investments, including into the European Union (EU).…

With the constant change in the global business environment, tax functions are continuously asked to “do more with less.” To comply with new reporting requirements, many companies are utilizing older aftermarket or “bolt-on” solutions and…

The Consolidated Appropriations Act, 2021 (“CAA”) increased the business expense deduction for food or beverages provided by a “restaurant” from 50 percent to 100 percent through 2022. All other business meals deductions remain subject to the lower…

While the first three months of this year have been filled with many twists and turns, yesterday was remarkable even by 2021 standards. Because yesterday’s events have required us to revise our thinking regarding how Democrats’ major legislative…

Article was published on Thomson Reuters’ Taxnet Pro, April 2021 Over the past 48 hours, the White House and senior members of Congress have released high-level policy proposals spanning numerous areas of the Internal Revenue…

On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (“Rescue Plan”). The Rescue Plan contains numerous provisions to help alleviate the impact of the COVID-19 pandemic on individuals and businesses. This…

Nearly a year into work from home orders and COVID-19, we can reflect on the one-year anniversary of California’s worker classification law, Assembly Bill 5 (“AB 5”), which was signed into law in September 2019 and effective January 1, 2020. AB 5…

Now in our fourth year under the Tax Cuts and Jobs Act of 2017, we’ve seen the new tax regime stretched to its extreme to accommodate a starkly different economy than that of 2017. A tax system built with an optimistic outlook is now facing an…

In an effort to raise revenue, Maryland recently passed the nation’s first tax on digital advertising services (House Bill 732), which was subsequently vetoed by Governor Larry Hogan. On February 12, the Maryland legislature overrode the Governor’s…

While every new year brings new opportunities and possibilities, during the first six weeks of 2021 we have already seen a seismic shift in the political (and tax law) landscape. With the Democratic Party winning unified control of Congress and the…

Today, the final carried interest regulations were published in the Federal Register. The final regulations generally adopt the proposed regulations that were issued in August 2020. However, there are a few noteworthy (and generally taxpayer…