The ability of holding companies to recover VAT on costs incurred continues to be hotly contested by HM Revenue & Customs. As such, companies must plan in a careful and timely manner to protect their VAT recovery regarding refinancing, restructuring deal transactions, and ongoing operating costs. There have been several recent developments in UK and
Taxes
Tax law prior to January 1, 2018 allowed you to defer capital gains taxes when you exchange one property with another similar property (also known as a Like-Kind exchange). Relying on this tax law and the murky crypto tax guidance that existed before 2018, some cryptocurrency holders applied like-kind exchange treatment to crypto-to-crypto trades and
In this installment of Willis Weighs In, Tax Notes contributing editor Benjamin M. Willis talks with Mark Oberstaedt and Ken Ahl, partners at Archer, about their help with a major taxpayer victory regarding foreign bank account report penalties. Here are a few highlights from their discussion, edited for length and clarity. Benjamin M. Willis: Today we’ll be discussing [foreign bank account
The Biden administration has released the Green Book, which details what they wish for as changes to the way income, and specifically capital gains are taxed. Here is a quick summary of the proposed changes: The top marginal individual income tax rate rises from 37% to 39.6%. The top individual income tax bracket begins at $452,700,
If you do not learn from your mistakes you are doomed to repeat them. In Estate Planning, if you do not learn from other’s mistakes, you are likely to repeat them. Mistakes in the Estate Planning of high profile celebrities is one very good way to learn the lesson of what not to do. Here are eight celebrity
DOJ is sending a message to tax professionals – particularly CPAs – who are involved in the syndicated conservation easement (SCE) industry. The message is “Be afraid. Be very afraid.” That is my reading of a recent press release about Georgia CPA Herbert E. Lewis indicted for SCE schemes involving fraudulent charitable contributions. DOJ releases like to lay
My column in Tax Notes often defends the actions of the IRS. Being tasked with administration of the IRC is no small chore, particularly when Congress leaves the agency deprived of adequate funding. That being said, this week’s topic offers a critical observation on the IRS’s litigation position on the applicability of foreign and religious law for federal estate tax
As the partisan battle heats up over President Biden’s ambitious infrastructure plan—and the tax increases to pay for it—the fate of the package will largely be decided by who can best frame its tax hikes. Biden wants to raise taxes on corporations by about $2 trillion, excluding its “green energy” tax credits. The president and
Still haven’t received your tax refund for tax year 2020? There were nearly 12 million returns in processing, according to the latest Internal Revenue Service filing season statistics, as of June 11—20 business days after the May 17, 2021 filing deadline and. That’s double the amount of returns in processing eight business days after the
Equity compensation for employees is booming. As stock markets surge, companies find rejuvenated value in granting equity to employees, not just to executives. Those employees, in turn, are getting ever more comfortable with stock investing via online trading apps. All of this means that the need for financial-planning advice is also booming, especially for employees
The Biden administration has released the Green Book, which details what they wish for as changes to the way Capital Gains are taxed. Here is a quick summary in contrast to existing laws. Current law Green Book Proposal Minimum tax 20% 20% Maximum tax 20% Max ordinary income rate (over $1 million) Now 40.8% When tax is due When assets are
The American Rescue Plan expanded the Child Tax Credit (or CTC) to $3,000 per qualifying child between the ages of 6 and 17 or under (thus expanding eligibility for an additional year) and further increased the credit to $3,600 per qualifying child under age 6 for tax year 2021 only (and income thresholds apply). The
As recent letters to taxpayers who might be eligible for the advance child tax credit indicated would happen, the IRS is in the midst of launching online portals to help families navigate the advance credit for 2021. This is the next big step in implementing the expanded benefit before monthly distributions of the advance credit begin in
The leaders of the world’s seven richest democracies ended their meeting in Britain on Sunday. This episode of What’s Ahead explains why other than pledging to get more Covid-19 vaccines to poorer nations, this ballyhooed confab was a big-time disappointment. Regarding President Biden’s promise of tough and united action against China, especially on its human
The Internal Revenue Service today updated its Child Tax Credit information page with FAQs and a new online tool to reach low-income people who don’t normally file tax returns. The American Rescue Act’s enhanced child tax credit basically means that 36 million families with kids get more money in their pockets earlier this year—instead of
In this episode of Tax Notes Talk, Professor Patricia A. Cain of the Santa Clara University School of Law discusses the unique tax challenges faced by members of the LGBTQ community in the past and today. This transcript has been edited for length and clarity. David D. Stewart: Welcome to the podcast. I’m David Stewart, editor in chief of Tax
No one likes paying taxes, and no one likes being audited. If you are audited, you should hire someone to represent you as there are risks in handling it yourself. For one thing, most criminal IRS cases come out of regular old civil audits and even simple interactions can go south. A good example of
We’re not in the midst of a global war — traditionally one of the greatest drivers of tax innovation — but some recent rhetoric surrounding international tax reform has adopted a bit of that flavor. In the heady, early days of the OECD’s base erosion and profit-shifting 2.0 project, the constant message streaming from the OECD’s Paris
Differences in Opinion on Racism and Diversity- Florida Lawyers Caught in the Middle Although “[a] simple letter to the Business Law Section…would have sufficed”, the Florida Supreme Court has, on its own motion, made law that denies continuing legal education credit to Florida lawyers for programs presented after April 15 that require diversity among course
The Covid-19 pandemic made many pre-existing economic inequalities worse, including the precarious situation of Black and non-white workers and the pressures on women to juggle work and care responsibilities. The pandemic also magnified economic pressures on vulnerable older workers, and our post-pandemic economic and equity policies must include them. Why do older workers matter to the economy? First, they make up
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