Tax Policy

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On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (H.R. 1, hereafter the “Revised House Bill”).  The Revised House Draft Bill contains certain changes to the original bill that was released on May 12, 2025 by the House Ways and Means Committee (the “Original House Draft…

June 2025 – The UK Government has published its response to the consultation on its proposal to change the tax treatment of carried interest, confirming the expected final shape of the new regime which will take effect from April 2026.

The reforms, first announced in October 2024, mark a significant…

Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill in the House of Representatives. The bill would apply to taxable years beginning after December 31, 2025, which could include…

On May 20, 2025, California’s Franchise Tax Board (“FTB”) released changes to the proposed regulations (“Draft Regulations”) that would amend the rules regarding market-based sourcing for sales other than sales of tangible personal property.  This is the latest step by the FTB in the long-running process toward formally adopting the amendments first approved in 2016, which we described in a September 2024 blog post when FTB released an updated draft of the amendments. 

On Thursday May 22, the House of Representatives passed the One Big Beautiful Bill Act (H.R. 1, hereafter the “Bill”). The Bill will now be considered by the U.S. Senate.

The following is a summary of some of the key provisions that have been changed from the version…

Update (6/18/2025): On June 16, 2025, the Senate released its revised draft of the tax legislation (the “Senate Draft Bill”).  Neither of the two proposed changes that would have been particularly relevant for the sports industry, as described in our previous blog post (shown below), was included in…

On May 18, 2025, the House Budget Committee approved the legislation entitled, “The One, Big, Beautiful Bill” (the “House Bill”). The bill is expected to be revised by the House Rules Committee before being sent to the House floor for a vote.

The House Bill extends…

On April 17, 2025, the U.S. Internal Revenue Service (the “IRS”) issued Notice 2025-23 (the “Notice”), announcing its intention to withdraw the recently released final regulations final regulationsthat classify certain partnership related party basis shifting transactions and substantially similar transactions as “transactions of interest”. The Notice provides taxpayers and their…

Introduction

On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and substantially similar transactions as transactions of interest, a type of reportable transaction, which requires disclosure for the taxpayer and its…