Base Erosion and Profit Shifting

A step closer to agreement on taxation of the digital worldThe Proposed BEAT Regulations View More…

BEAT

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand NowComparison of the Biden Administration and Senate Finance Committee International Tax Proposals View More…

Blockchain

Senate Finance Committee Requests Public Comments on Digital Asset TaxationIncome, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation View More…

CARES Act

Coronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax ProvisionsIRS issues new FAQs on the interaction between the employee retention tax credit and PPP loans in M&A transactions View More…

Clawback Rules

Tax Consequences of Compensation ClawbackProposed Clawback Rules Released View More…

Compliance

FATCA: Significant Relief in New Proposed RegulationsDivision of Corporate Finance Releases Updated C&DIs View More…

Coronavirus

COVID-19: OECD updates its guidance on residence and permanent establishmentsCoronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax Provisions View More…

Corporate tax

UK Supreme Court confirms no deduction for expenses related to share and asset saleTreasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to Develop Further Partnership Guidance. View More…

Corporate Taxation

UK Supreme Court confirms no deduction for expenses related to share and asset saleSupreme Court Rules on Moore v. U.S. – Upholds Mandatory Repatriation Tax View More…

Cost Recovery

Tax Relief for American Families and Workers Act of 2024Impact of Recent Tax Legislation on M&A Transactions View More…

Cost-Sharing Agreements

Tax Court Rules on Inclusion of Stock-Based Compensation Costs in Cost-Sharing Agreements View More…

Cryptocurrency

Senate Finance Committee Requests Public Comments on Digital Asset TaxationIRS answers some, but not all, questions in long-awaited cryptocurrency guidance View More…

Dodd-Frank

Final Pay Ratio RulesProposed Clawback Rules Released View More…

Employee Benefits

COVID-19 Impact on Executive Compensation - Amending Performance Goals under Equity and Other Incentive AwardsThe CARES Act and Compensation – What Employers Need to Know View More…

Environment

Recent Updates from the IRS and Treasury on the Superfund Chemical TaxPresident Biden Signs Inflation Reduction Act into Law View More…

European law

EU Commission publishes draft directive to remove tax driven debt-equity biasCayman Islands added to the EU blacklist of non-cooperative jurisdictions for tax purposes View More…

Executive Compensation

IRS Creates Standardized Form for Section 83(b) ElectionsBlueCrest – the Upper Tribunal considers the salaried member rules View More…

Exempt Organizations

U.S. District Court Finds Mayo Clinic Qualifies as an “Educational Organization”; Awards $11.5M UBTI RefundRegulations on Executive Compensation Excise Tax (Section 4960) for Tax-Exempt Employer and Their Affiliates Finalized View More…

FASB/Accounting

FASB Updates for 2016 Financial Statements Could Impact Permissible Adjustments under Code Section 162(m) View More…

financial products

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand NowLIBOR Transition: U.S. Tax Guidance From the IRS View More…

FIRPTA

Final Regulations on Domestically Controlled REITsNew Proposed Regulations Would Impact the Determination of Domestically Controlled REIT and Structures for Sovereign Wealth Funds’ US Real Estate Investments View More…

GILTI

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand NowComparison of the Biden Administration and Senate Finance Committee International Tax Proposals View More…

In the news

Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxPost Election – Expect Tax Legislation View More…

Incentive Stock Options

To Accelerate or Not? Potential Tax Planning in Light of Proposed Reforms to Code Section 162(m)IRS Releases Guidance on Treatment of Incentive Stock Options in Reorganizations View More…

International Taxation

Supreme Court Rules on Moore v. U.S. – Upholds Mandatory Repatriation TaxProposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock View More…

Inversions

House of Representatives and Senate Conferees Reach Agreement on the Tax Cuts and Jobs Act (H.R. 1): Description of the Conference Agreement and Differences from House and Senate VersionsU.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and Outstanding Differences to be Resolved in Conference View More…

IRS

Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxIncrease in Tax Audits of Use of Private Aircraft, a/k/a “Corporate Jets” View More…

Mergers & Acquisitions

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate StockIRS and Treasury Provide Guidance on the Excise Tax on Repurchases of Corporate Stock under Section 4501 View More…

Notable Decisions

Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxSupreme Court Rules on Moore v. U.S. – Upholds Mandatory Repatriation Tax View More…

NYS / NYC

Tax Reform: UBTI Guidance on Qualified Transportation Fringe Benefits View More…

Opportunity Zones

Final Regulations on Opportunity ZonesThe Second Set of Proposed Opportunity Zone Regulations View More…

Partnership Taxation

Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxTreasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to Develop Further Partnership Guidance. View More…

Pay Ratio Regulations

SEC Adopts Additional Guidance on CEO Pay Ratio RuleLooking Ahead to the 2018 Proxy Season: Preparing for CEO Pay Ratio Rules Disclosure Requirements View More…

Performance-Based Compensation

Tax Court Holds That Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxCOVID-19 Impact on Executive Compensation (Leave of Absence) View More…

Privacy & Data Security

IRS Provides Some Relief after Data Hacks View More…

Proskauer Tax Department Announcements

Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxPost Election – Expect Tax Legislation View More…

Proxy Disclosure

Division of Corporate Finance Releases Updated C&DIsSEC Adopts Additional Guidance on CEO Pay Ratio Rule View More…

Real Estate

No Money? No Problem: Recent IRS Favorable Guidance Regarding a REIT’s First YearThe IRS and Senator Warren Raise Concerns about Lodging and Health Care REITs View More…

REITs

No Money? No Problem: Recent IRS Favorable Guidance Regarding a REIT’s First YearThe IRS and Senator Warren Raise Concerns about Lodging and Health Care REITs View More…

Restructuring

Proposed Regulations on Built-in Gains and Losses under Section 382(h) View More…

RIC (BDCs)

New Guidance Allows Publicly-Offered REITs and RICs to Issue up to 90% of Qualifying Dividends in the REIT or RIC’s Own Stock Through June 2022 “Passthrough Deduction" Regulations for RICs Finalized with No Major Changes View More…

SEC

COVID-19 Impact on Executive Compensation - Amending Performance Goals under Equity and Other Incentive AwardsCOVID-19 Impact on Executive Compensation – Salary/Wage Reductions View More…

Section 162(m)

IRS Releases Preliminary Guidance on Certain Aspects of the Amended Section 162(m) ProvisionsTo Accelerate or Not? Potential Tax Planning in Light of Proposed Reforms to Code Section 162(m) View More…

Section 199A

 “Passthrough Deduction" Regulations for RICs Finalized with No Major Changes View More…

Section 355

Tax Planning is Crucial to Achieve Potential Spin-Off BenefitsIRS Resumes Issuing Transactional Spin-Off Rulings View More…

Section 409A

COVID-19 Impact on Executive Compensation - Amending Performance Goals under Equity and Other Incentive Awards View More…

Sovereign Wealth Funds

New Bill Would Deny Section 892 Benefits To Certain Sovereign Wealth Funds View More…

State Taxation

California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules - Implications for Asset ManagersCalifornia Franchise Tax Board (FTB) to Apply Market-Based Sourcing Rules to Nonresident Directors of California Based Corporations View More…

Stock Buyback Excise Tax

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate StockIRS and Treasury Provide Guidance on the Excise Tax on Repurchases of Corporate Stock under Section 4501 View More…

Tax

Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxPost Election – Expect Tax Legislation View More…

Tax Cuts and Jobs Act

Post Election – Expect Tax LegislationIncrease in Tax Audits of Use of Private Aircraft, a/k/a “Corporate Jets” View More…

Tax Policy

Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxIncrease in Tax Audits of Use of Private Aircraft, a/k/a “Corporate Jets” View More…

Tax Reform

Increase in Tax Audits of Use of Private Aircraft, a/k/a “Corporate Jets”Treasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to Develop Further Partnership Guidance. View More…

U.S. Inbound Real Estate Investment

Final Regulations on Domestically Controlled REITsProposed Regulations Provide Clarity for Qualified Foreign Pension Fund Exception View More…

U.S. Legislation

Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxPost Election – Expect Tax Legislation View More…

UBTI

U.S. District Court Finds Mayo Clinic Qualifies as an “Educational Organization”; Awards $11.5M UBTI RefundProposed Regulations on UBTI Provide Guidance to Tax-Exempt Organizations Making Fund Investments View More…

UK Budget

Massive U-Turn on Mini BudgetUK Mini Budget 2022 View More…

UK Tax

UK Supreme Court confirms no deduction for expenses related to share and asset saleHMRC updates guidance on UK tax status of non-UK entities and US LLCs post Anson View More…

Uncategorized

Taxing carried interest in the UK: the new regime announced in the Labour government’s Autumn Budget 2024Increase in Tax Audits of Use of Private Aircraft, a/k/a “Corporate Jets” View More…

Wages

Tax Court Holds That Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment TaxCalifornia “Waiting Time Penalties” Are Not Wages For Federal Income Tax Purposes View More…

Withholding and FATCA

Senate Finance Committee Requests Public Comments on Digital Asset TaxationProposed Regulations Provide Clarity for Qualified Foreign Pension Fund Exception View More…