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5 Key Takeaways | Artificial Intelligence: What Tax Professionals Need to Know
Avoiding Tax Consequences During Oil & Gas Restructurings
On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a taxpayer-friendly legislative proposal. While it is uncertain whether the TAS Act...more
Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more
Residence may seem to be a relatively simple thing to determine. It’s where you live, right? Well, leave it to the Internal Revenue Code to complicate this question. There are different tests for residency when it comes to...more
On Monday, May 12, House Ways and Means Committee (“Committee”) Chairman Jason Smith (R-MO) released text of the Committee’s tax title for the FY 2025 budget reconciliation bill—the amendment in the nature of a substitute...more
On Tuesday afternoon, May 13, the Ways and Means Committee (“Committee”) started its markup of the tax title for the FY2025 budget reconciliation bill. The Committee favorably reported the bill on Wednesday morning, May 14,...more
On May 13, 2025, the Brazilian Federal Revenue Service (IRS) published Normative Instruction no. 2,265/2025, which amends the Brazilian black and gray lists established by Normative Instruction no. 1,037/2010....more
Kilpatrick’s David Hughes recently moderated a panel discussion at the ABA Tax Section May 2025 Meeting in Washington, D.C. on the topic of “Retroactive Taxation: Legal Framework, State Applications, and Policy Implications.”...more
BALTIMORE—Bill Introduced to Address Housing Shortage- On Monday, Mayor Brandon Scott (D) introduced his Housing Options & Opportunity Act, which aims to expand zoning laws for multi-family homes and provide more housing...more
Over the past 25 years, the Cayman Islands have established themselves as a leading jurisdiction for alternative investment funds, with nearly 13,000 regulated open-ended funds and over 17,000 regulated closed-ended funds. As...more
California has become a battlefield for state versus tribal governance. As of May 6, 2025, the Morongo Band of Mission Indians (Morongo Band), a federally recognized Indian Tribe located in the State of California, filed suit...more
Kazakhstan will soon adopt a new tax code, with the bill currently in Parliament. It is expected that the new tax code will be adopted this year and come into force beginning 2026. This LawFlash summarizes the general...more
What is an EIN? An EIN is a federal tax ID number for an entity, estate, trust, or other organization. For example, the following are generally required to obtain an EIN: partnerships, limited liability companies (“LLC”),...more
This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
PAUTAS: STF – CONTROLE CONCENTRADO E REPERCUSSÃO GERAL | STJ – REPETITIVOS | TCU – PLENÁRIO | CÂMARA DOS DEPUTADOS | SENADO FEDERAL - Prezados e prezadas, O “Brasília em Pauta” é um boletim semanal preparado pela...more
Global Capability Centers (GCCs) have become strategic hubs for multinational corporations, financial institutions and other organizations because they can provide centralized control over high-value technology and...more
News that Steward Health Care executives may lose millions in unqualified retirement savings due to the company's use of a "rabbi trust" has sent a jolt through the ranks of corporate leadership. Steward's deferred...more
With the end of the 2025 legislative session fast approaching, legislators are working to approve the omnibus finance bills necessary to implement a FY 2026-2027 Biennial Budget. Legislative leaders and the Governor continue...more
The IRS has announced the 2026 cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs), and excepted benefit health reimbursement arrangements...more
By June 7, 2025, Gov. Bob Ferguson is expected to sign legislation into law that would increase funding for Washington State's Education Legacy Trust Account (ELTA) by raising the capital gains and estate tax rates. ...more
Cannabis companies are increasingly taking non-280E positions on their current year federal income tax returns, while many, such as public “MSOs,” have amended prior years’ returns to reflect this position. Foley Hoag’s Tax...more
On May 1, 2025, the Internal Revenue Service (IRS) released Revenue Procedure 2025-19, which provides the 2026 inflation adjusted limits related to Health Savings Accounts (HSAs) and High Deductible Health Plans (HDHPs)....more
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
On 28 April 2025, the UK government published draft legislative amendments to: - Align the UK’s domestic tax rules on permanent establishments (PE) with the 2017 Organisation for Economic Co-operation and Development (OECD)...more
The federal rule that would have required crypto platforms to report users’ transactions to the IRS has officially been scrapped. President Trump signed a joint congressional resolution overturning the so-called DeFi...more
The Internal Revenue Service (IRS) recently announced (see Revenue Procedure 2025-19) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs), and...more