Tax News
Bringing you the latest tax and accounting updatesIRS – Tax Tips
- New Proposed Regulations Would Impact the Determination of Domestically Controlled REIT and Structures for Sovereign Wealth Funds’ US Real Estate Investmentsby Muhyung (Aaron) Lee, Amanda H. Nussbaum, David S. Miller, Richard M. Corn, Jeremy Naylor and Carrie Slaton on January 13, 2023 at 7:57 pm
On December 28, 2022, the Internal Revenue Service (the “IRS”) and the Treasury Department released proposed regulations (the “Proposed Regulations”) under sections 892 and 897 of the Internal Revenue Code (the “Code”).[1] If finalized as proposed, the Proposed Regulations would prevent a non-U.S. person from investing through a wholly-owned U.S. corporation in order to cause...… Continue Reading
- U.S. District Court Finds Mayo Clinic Qualifies as an “Educational Organization”; Awards $11.5M UBTI Refundby Richard M. Corn, Amanda H. Nussbaum, David S. Miller, Stuart Rosow and Carrie Slaton on January 3, 2023 at 10:11 pm
Tax-exempt organizations, while not generally subject to tax, are subject to tax on their “unrelated business taxable income” (“UBTI”). One category of UBTI is debt-financed income; that is, a tax-exempt organization that borrows money directly or through a partnership and uses that money to make an investment is generally subject to tax on a portion...… Continue Reading
- Massive U-Turn on Mini Budgetby Richard Miller, Emma C. McDonnell and Robert E. Gaut on October 18, 2022 at 9:07 am
As has been widely reported, a number of the Mini Budget proposals (summarised in our recent Tax Blog) have been scrapped. The new Chancellor of the Exchequer Jeremy Hunt announced these measures claiming that they are estimated to raise £32 billion in taxes every year. More tax rises and spending cuts are expected to be...… Continue Reading
- UK Mini Budget 2022by Richard Miller, Emma C. McDonnell and Robert E. Gaut on September 23, 2022 at 4:50 pm
UK Mini Budget 2022 The Chancellor today unveiled the UK’s 2022 Growth Plan which has been described as being “the biggest package of tax cuts in generations”. We have summarised here the tax changes that we think will be of interest to our client base. UK corporation tax: the main corporation tax rate that was...… Continue Reading
- President Biden Signs Inflation Reduction Act into Lawby David S. Miller, Stuart Rosow, Amanda H. Nussbaum, Martin T. Hamilton, Arnold P. May, Tyler J. Moser and Rita N. Halabi on August 16, 2022 at 8:15 pm
On August 16, 2022 President Biden signed the Inflation Reduction Act of 2022 (the “IRA”) into law. The IRA includes a 15% corporate alternative minimum tax, a 1% excise tax on stock buybacks and a two-year extension of the excess business loss limitation rules. The IRA also contains a number of energy tax provisions. I....… Continue Reading
- Senate Democrats Reach Agreement to Pass Inflation Reduction Actby David S. Miller, Amanda H. Nussbaum, Stuart Rosow, Martin T. Hamilton and Rita N. Halabi on August 12, 2022 at 1:53 pm
On August 7, the Senate passed the Inflation Reduction Act of 2022 (the “IRA”). The tax provisions in the bill that was passed vary from the bill that was originally released on July 27, 2022 by Senator Joe Manchin (D-W.Va.) and Senate Majority Leader Chuck Schumer (D-NY) in four significant respects: The carried interest proposal...… Continue Reading
- A Summary of Inflation Reduction Act’s Main Energy Tax Proposalsby David S. Miller, Amanda H. Nussbaum, Martin T. Hamilton, Tyler J. Moser and Rita N. Halabi on August 8, 2022 at 2:16 pm
On August 7, the Senate passed the Inflation Reduction Act of 2022 (the “IRA”). The IRA contains a significant number of climate and energy tax proposals, many of which were previously proposed in substantially similar form by the House of Representatives in November 2021 (in the “Build Back Better Act”). Extension and expansion of production...… Continue Reading
- A Summary of Inflation Reduction Act’s Main Tax Proposalsby David S. Miller, Amanda H. Nussbaum, Stuart Rosow, Arnold P. May, Jeremy Naylor, Martin T. Hamilton and Rita N. Halabi on August 4, 2022 at 2:51 pm
On July 27, 2022, Senator Joe Manchin (D-W.Va.) and Senate Majority Leader Chuck Schumer (D-N.Y.) released the Inflation Reduction Act of 2022 (the “IRA”). The IRA contains only two non-climate and non-energy tax proposals – a 15% corporate alternative minimum tax and a provision significantly narrowing the applicability of preferential long-term capital gain rates to...… Continue Reading
- HMRC Announces Welcome Changes to the QAHC Regimeby Stephen Pevsner and Philip Gilliland on July 26, 2022 at 3:13 pm
On 20 July 2022, the UK government published draft legislation for the Finance Bill 2022-2023. Of particular interest are amendments to be made to the qualifying asset holding company (QAHC) regime that was introduced from 1 April this year. The regime is part of the UK government’s attempt to increase the attractiveness of the UK...… Continue Reading
- Summary of the Biden Administration’s Fiscal Year 2023 Green Book Tax Proposalsby David S. Miller, Amanda H. Nussbaum, Stuart Rosow, Richard M. Corn, Robert A. Friedman, Martin T. Hamilton, Arnold P. May and Rita N. Halabi on July 21, 2022 at 3:02 pm
On March 28, 2022, the Biden Administration released the Fiscal Year 2023 Budget, and the “General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals,” which is commonly referred to as the “Green Book.” The Green Book summarizes the Administration’s tax proposals contained in the Budget. The Green Book is not a proposed legislation and each...… Continue Reading
- New Proposed Regulations Would Impact the Determination of Domestically Controlled REIT and Structures for Sovereign Wealth Funds’ US Real Estate Investmentsby Muhyung (Aaron) Lee, Amanda H. Nussbaum, David S. Miller, Richard M. Corn, Jeremy Naylor and Carrie Slaton on January 13, 2023 at 7:57 pm
On December 28, 2022, the Internal Revenue Service (the “IRS”) and the Treasury Department released proposed regulations (the “Proposed Regulations”) under sections 892 and 897 of the Internal Revenue Code (the “Code”).[1] If finalized as proposed, the Proposed Regulations would prevent a non-U.S. person from investing through a wholly-owned U.S. corporation in order to cause...… Continue Reading
- U.S. District Court Finds Mayo Clinic Qualifies as an “Educational Organization”; Awards $11.5M UBTI Refundby Richard M. Corn, Amanda H. Nussbaum, David S. Miller, Stuart Rosow and Carrie Slaton on January 3, 2023 at 10:11 pm
Tax-exempt organizations, while not generally subject to tax, are subject to tax on their “unrelated business taxable income” (“UBTI”). One category of UBTI is debt-financed income; that is, a tax-exempt organization that borrows money directly or through a partnership and uses that money to make an investment is generally subject to tax on a portion...… Continue Reading
- A New(ish) Chemical Excise Tax Effective July 2022by Amanda H. Nussbaum, Aliza Cinamon, T.J. Ruane and Thomas Multari on May 13, 2022 at 3:18 pm
After a more than 26 year hiatus, on July 1, 2022, the Superfund chemical excise tax (the “Superfund Chemical Tax”) will again become effective. This excise tax, reinstated by the passage of the Infrastructure Investment and Jobs Act,[1] is imposed on manufacturers, producers, and importers of certain chemicals and chemical substances. As discussed below, the...… Continue Reading
- The Biden Administration Proposes Changes to the Taxation of Cryptocurrency Transactionsby Robert A. Friedman, Martin T. Hamilton, David S. Miller, Amanda H. Nussbaum, Stuart Rosow and Rita N. Halabi on May 5, 2022 at 2:30 pm
On March 28, 2022, the Biden Administration proposed certain very limited changes to the taxation of cryptocurrency transactions. The proposals do not change the current treatment of cryptocurrency as property for federal income tax purposes, and do not address any of the fundamental tax issues that cryptocurrency raise. I. Apply Securities Loan Rules to Digital...… Continue Reading
- Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stockby Dan Paulos, Amanda H. Nussbaum and Martin T. Hamilton on January 25, 2022 at 7:23 pm
On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally would treat domestic partnerships as aggregates of their partners (rather than as entities) for purposes of determining income inclusions under the Subpart F provisions applicable...… Continue Reading
A Primer On Education Tax Credits
When preparing for college, students and parents can easily list the costs like tuition, fees, supplies and room and board. But do you spend enough time considering the tax benefits associated with a college education? Lucky for you there are a number of education tax...