The One, Big, Beautiful Bill Act (H.R. 1), recently passed by the U.S. House, introduces major changes to the Global Intangible Low-Taxed Income (GILTI) regime that could impact multinational corporations. It makes the current 49.2% GILTI deduction rate permanent...
A small issue bond is one type of conduit bond, referred to as a private activity bond, which provides a loan to a nongovernmental third-party borrower for use in developing projects that benefit the public. Qualified small issue bonds are tax-exempt bonds issued...
The budget reconciliation bill passed the House of Representatives by a one-vote margin, 215 to 214, and soon will be considered by Senate committees. The day before the House vote, the Rules Committee had voted 8-4 along party lines to approve a rule on the One...
Working with the Energy and Commerce and the Agriculture Committees, the U.S. House of Representatives’ Ways and Means Committee advanced its portion of the “One, Big, Beautiful Bill Act” on May 15. The Energy and Commerce and Agriculture Committees...
Succession planning is a critical aspect of managing small, closely held businesses, as the unexpected departure of a key leader can significantly disrupt operations and challenge the business's legal continuity. Unlike large, publicly traded companies, these...
The United States has tax treaties with nearly 70 countries to prevent double taxation and curb tax evasion. These treaties, based on Article II, Section 2 of the U.S. Constitution, are reciprocal and generally apply to both countries involved. For U.S. citizens...
With multiple European and South American countries promising an affordable retirement, Americans are increasingly renouncing U.S. citizenship and expatriating, some gaining citizenship, outside the United States. Relinquishing U.S. citizenship (or green card status...
Harvard University’s tax-exempt status has been questioned by the Trump Administration—with Harvard responding that there is no legal basis for a revocation. The Administration’s action impacting Harvard flows from its letter on policy changes...
The most prominent tax characteristic of a partnership or LLC is that these entities are flow-through entities for tax purposes. Consequently, the entities do not pay taxes themselves. Rather, they report to the IRS their income and the partners' or members'...
Tariffs are generally considered a regressive form of taxation—that is, a tax burden that falls more heavily on lower-income individuals than on higher-income individuals, relative to their incomes. When tariffs are applied, the cost of goods subject to the...
Real property transactions involving easements granted in the name of conservation can yield tax deduction benefits to the grantor. While the validity of charitable contributions in this area is subject to scrutiny and deduction claims are prone to challenge by...
As the population ages and more taxpayers live on fixed incomes, both federal and state governments face challenges in determining the appropriate level of taxation for retirees. For federal income tax purposes, retirement income is generally fully includable in...
Explore the taxation of business profits under U.S. international tax treaties, focusing on the critical role these treaties play in preventing double taxation and clarifying cross-border tax obligations. This practice note explores the concept of permanent establishment...
In 2025, navigating the IRS's tax collection process is more critical than ever, as changing tax laws and economic shifts demand vigilance from both individuals and businesses. The IRS, armed with a formidable team of Revenue and Appeals Officers, is tasked...