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Income Taxes › Tax Liability

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Rosenberg Martin Greenberg LLP

Will Maryland Provide Value in Exchange for 2026 Tax Increases?

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Maryland Governor Wes Moore is expected to sign (if he has not by the date of this publication) House Bill 0350 in the coming weeks. The final version of the bill includes several major tax increases to address budget...more

Goodwin

UK Salaried Member Employment Tax Rules - Recent Developments

Goodwin on

This client alert discusses recent developments relevant to members of UK LLPs in respect of the UK’s salaried member employment tax rules. In particular, it focuses on recent developments in relation to Condition B (the...more

Fox Rothschild LLP

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales

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An installment sale occurs when property is disposed of and at least one payment is received after the tax year of the disposition. See I.R.C. § 453. Under a standard installment sale, the buyer makes scheduled payments to...more

McDermott Will & Emery

Economic Ownership of Shares Transferred as Collateral

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Dividends from shares are taxable for shareholders, even if the dividends do not remain with them economically. This (not entirely new) finding can be gleaned from a recent Federal Fiscal Court (BFH) ruling in which the...more

Blank Rome LLP

Cannabis ESOPs Provide Solutions for Operators

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As we enter Q2 of 2025, the cannabis industry has become increasingly pessimistic about the elimination of Section 280E of the Internal Revenue Code, whether via rescheduling or otherwise. Rescheduling appears unlikely in the...more

DLA Piper

Top Ten State Tax Considerations for Israeli Companies Operating in the US

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Although Israeli companies operating in the US often focus on federal tax concerns, US state and local taxes (SALT) have the potential to significantly increase tax liabilities. For example, if a company does not collect...more

Mayer Brown

Caractérisation d’un établissement stable dans le domaine du digital en présence d’une activité occulte

Mayer Brown on

Le Conseil d’Etat confirme l’existence d’un établissement stable et caractérise une activité occulte en l’absence de déclaration de cet établissement en France par application de l’article L. 169 du Livre des procédures...more

Mandelbaum Barrett PC

The $5 Million Hush Money Payment in White Lotus Season 3

Mandelbaum Barrett PC on

The explosive finale of White Lotus Season 3 left fans with more than just plot twists—it raised fascinating legal and tax questions. Chief among them: what are the implications of Greg’s $5 million wire transfer to Belinda,...more

Cadwalader, Wickersham & Taft LLP

Tax Court Calls Bluff on Hedge Fund’s Basket Option Contracts

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The Tax Court recently held that a hedge fund’s basket option contracts were in substance tax ownership of the underlying basket securities. The hedge fund, through its affiliated entities, entered into 10 basket option...more

Rivkin Radler LLP

State Taxation of a Nonresident’s Gain from the Sale of Stock –The Shot Heard Round the Country?

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Last month, Bloomberg carried an article about a “small but growing trend” of states that are either cutting their individual income taxes or phasing them out entirely. According to the article, the states adopting these...more

Ballard Spahr LLP

Finally Received the Employee Retention Credit? Now What? A Guide to ERC Income Tax Consequences

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It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more

Patterson Belknap Webb & Tyler LLP

Section 83(b) Elections — Should You Pay Taxes Now?

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In startups and early-stage companies, founders often receive restricted equity grants as compensation for their services. With some planning, founders can potentially lower the taxes they pay on the appreciation of the...more

Foster Garvey PC

Hobby Loss Rules Revisited

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With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more

Bowditch & Dewey

Made a Mistake on Your Tax Return? What to Do if You Filed Incorrectly

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Mistakes happen, and the tax law can be complex and ambiguous. The question becomes, what does a taxpayer do if they discover a mistake on their tax return? Should an amended tax return be filed? In some cases, the taxpayer...more

Bradley Arant Boult Cummings LLP

Mobile Workforce/Remote Worker Legislation Could Impact Your Business

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Well-respected House Ways & Means-Education Committee Chair Danny Garrett (R-Trussville) has introduced HB 379, a bill designed to provide guidelines and a safe harbor for employers who have traveling employees or remote...more

Farrell Fritz, P.C.

M&A Tax Concepts: What is a “Gross-up Payment,” and Why Does It Matter?

Farrell Fritz, P.C. on

Buying or selling a business is an exciting experience, and potentially lucrative opportunity for all parties. Most often, during the letter of intent / early negotiations phase, a “deal” is struck based primarily on economic...more

DLA Piper

Chile: Servicio de Impuestos Internos publica instrucciones sobre facultad de tasación y su aplicación a reorganizaciones...

DLA Piper on

El Servicio de Impuestos Internos (SII) dictó la Circular N°23 que imparte instrucciones sobre el nuevo texto del artículo 64 del Código Tributario. A modo de contexto, el SII tiene una facultad legal para tasar el precio o...more

Paul Hastings LLP

Crypto Tax Update – April 2025

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In light of the approaching April 15 tax filing deadline, this week’s update highlights recent developments in U.S. federal tax policy that may impact crypto firms and crypto holders....more

Buckingham, Doolittle & Burroughs, LLC

IRS Issues Guidance Simplifying Income Tax Compliance Related to the Employee Retention Credit

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The IRS recently released new FAQ guidance providing a simplified procedure for addressing income tax amendments and refund claims related to Employee Retention Credit (ERC) determinations. See IRS FAQs. Taxpayers claiming...more

Goulston & Storrs PC

Massachusetts Targets Founder’s Share Sale After Move…To New Hampshire

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The Massachusetts Court of Appeals has ruled that, in some situations, a former resident of the Commonwealth can be liable for Massachusetts income tax on the sale of shares in a Massachusetts-headquartered company even after...more

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

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On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Farrell Fritz, P.C.

Relocating? Be Sure to Add the IRS to Your Change of Address Checklist

Farrell Fritz, P.C. on

In a recent decision, the U.S. District Court for the Central District of California held that the Internal Revenue Service (“IRS”) did not violate Internal Revenue Code (“IRC”) Section 7433 or related regulations when it...more

Winthrop & Weinstine, P.A.

Legislative Top 5 – April 2025

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Deadlines! It has been a busy week at the State Capitol. In both the House and Senate, committees raced to meet the first and second bill deadlines of Friday, April 4 (collectively), while finance committee chairs in both...more

IR Global

Dubai’s New Tax Law For Foreign Banks

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The Emirate of Dubai in 2024 issued Law No. (1) of 2024 Concerning Tax on Foreign Banks Operating in the Emirate of Dubai. The Law’s passing is an essential step to clarify the applicability of separate tax laws for foreign...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

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Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

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