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Tax Talks

The latest updates and insights on tax law

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Base Erosion and Profit Shifting

Trump Administration Disavows the OECD Global Tax DealA step closer to agreement on taxation of the digital world 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

The One Big Beautiful Bill: Tax Reform 2025Coronavirus: President Trump Signs Consolidated Appropriations Act, 2021; Summary of the Tax Provisions View More…

Clawback Rules

Tax Consequences of Compensation ClawbackProposed Clawback Rules Released View More…

Compliance

Senators Crapo and Wyden Release Draft Bipartisan Taxpayer Rights LegislationFATCA: Significant Relief in New Proposed Regulations 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

Treasury and the IRS Release Final and Proposed Regulations on Section 892Tax Court Breaks New Ground on the Deductibility of Termination Fees with AbbVie Ruling View More…

Corporate Taxation

Treasury and the IRS Release Final and Proposed Regulations on Section 892Tax Proposals Potentially Being Considered by the U.S. House Budget Committee in Reconciliation 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

Tax Proposals Potentially Being Considered by the U.S. House Budget Committee in ReconciliationCOVID-19 Impact on Executive Compensation - Amending Performance Goals under Equity and Other Incentive Awards 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

FICA Tax: Navigating the Nonqualified Deferred Compensation Special Timing RuleExecutive Use of Corporate Aircraft: Navigating Tax, SEC Disclosure and Other Key Considerations View More…

Exempt Organizations

Eighth Circuit Affirms Mayo Clinic’s “Educational Organization” Status and UBTI RefundOne Big Beautiful Bill: Update on Provisions for Nonprofits View More…

FASB/Accounting

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

financial products

Treasury and the IRS Release Final and Proposed Regulations on Section 892Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand Now View More…

FIRPTA

Proposed Regulations Remove Look-Through Rule for Domestically Controlled REITsFinal Regulations on Domestically Controlled REITs View More…

GILTI

The One Big Beautiful Bill: Tax Reform 2025Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand Now View More…

In the news

Fifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment TaxTreasury and the IRS Release Final and Proposed Regulations on Section 892 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

Treasury and the IRS Release Final and Proposed Regulations on Section 892Proposed Regulations Remove Look-Through Rule for Domestically Controlled REITs 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

Fifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment TaxTreasury and the IRS Release Final and Proposed Regulations on Section 892 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

Recent Federal Privilege Ruling Related to AI Tools Has Implications for Routine Tax Advisor ArrangementsFifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment Tax View More…

NYS / NYC

New York Tax Court Approves Section 1031 “Drop & Swap” TransactionsUnsuccessful Taxpayer Change in Domicile from New York to Florida Shows that Courts will Follow the Money View More…

Opportunity Zones

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

Partnership Taxation

Fifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment TaxTreasury and the IRS Release Final and Proposed Regulations on Section 892 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

Fifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment TaxTreasury and the IRS Release Final and Proposed Regulations on Section 892 View More…

Proxy Disclosure

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

Real Estate

New York Tax Court Approves Section 1031 “Drop & Swap” TransactionsProposed Regulations Remove Look-Through Rule for Domestically Controlled REITs View More…

REITs

Proposed Regulations Remove Look-Through Rule for Domestically Controlled REITsNo Money? No Problem: Recent IRS Favorable Guidance Regarding a REIT’s First Year View More…

Restructuring

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

RIC (BDCs)

Proposed Regulations Remove Look-Through Rule for Domestically Controlled REITsProposed Changes to Interest Rate Tax Treatment for RICs View More…

SEC

Recent Federal Privilege Ruling Related to AI Tools Has Implications for Routine Tax Advisor ArrangementsCOVID-19 Impact on Executive Compensation - Amending Performance Goals under Equity and Other Incentive Awards 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

Proposed Changes to Interest Rate Tax Treatment for RICsThe One Big Beautiful Bill: Tax Reform 2025 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

Treasury and the IRS Release Final and Proposed Regulations on Section 892New Bill Would Deny Section 892 Benefits To Certain Sovereign Wealth Funds View More…

State Taxation

New York Tax Court Approves Section 1031 “Drop & Swap” TransactionsUnsuccessful Taxpayer Change in Domicile from New York to Florida Shows that Courts will Follow the Money 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

Recent Federal Privilege Ruling Related to AI Tools Has Implications for Routine Tax Advisor ArrangementsFifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment Tax View More…

Tax Cuts and Jobs Act

The One Big Beautiful Bill: Relevant Provisions for NonprofitsTax Proposals Potentially Being Considered by the U.S. House Budget Committee in Reconciliation View More…

Tax Policy

Fifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment TaxTreasury and the IRS Release Final and Proposed Regulations on Section 892 View More…

Tax Proposals

One Big Beautiful Bill: Update on Provisions for NonprofitsProposed Changes to Interest Rate Tax Treatment for RICs View More…

Tax Reform

Fifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment TaxTreasury and the IRS Release Final and Proposed Regulations on Section 892 View More…

U.S. Inbound Real Estate Investment

Proposed Regulations Remove Look-Through Rule for Domestically Controlled REITsFinal Regulations on Domestically Controlled REITs View More…

U.S. Legislation

Fifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment TaxSenator Tillis Introduced a Bill Taxing Proceeds of Litigation Financing Agreements View More…

UBTI

Eighth Circuit Affirms Mayo Clinic’s “Educational Organization” Status and UBTI RefundOne Big Beautiful Bill: Update on Provisions for Nonprofits View More…

UK Budget

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

UK Tax

UK Government Carried Interest Tax Reforms Consultation Process: No New Conditions, Territorial Limits ClarifiedBlueCrest - the Court of Appeal considers Condition B of the salaried members rules View More…

Uncategorized

Federal Rulings Ease COVID‑Era Interest, Penalty and Filing BurdensShare Buyback Qualified for Capital Treatment Where Undertaken for Genuine Trade Benefit 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…
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