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As of July 2025, 38 U.S. states and the District of Columbia have legalized sports betting in some form—either online, in-person, or both. This expansion follows the Supreme Court's 2018 decision to overturn the previous federal ban on sports...

Both the House and Senate versions of the One Big Beautiful Bill Act (OBBBA), passed by the House on May 22, 2025, and the Senate on July 1, 2025, phase out tax credits for wind, solar, and electric vehicle (EV) projects, rolling back incentives established...

Section 112020 of the “One Big Beautiful Bill Act” (OBBBA), House version, would expand the reach of the IRC § 4960 excise tax on compensation in excess of $1 million (equal to 21%, the corporate tax rate) paid to employees of an applicable...

In a stock purchase transaction, the outstanding stock of the target company is transferred directly by its stockholders to the purchaser, with a stock purchase agreement serving as the primary governing document. Tax professionals must thoroughly identify...

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...

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...

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...

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...

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...

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...

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...

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...

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...

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'...

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...

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...

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...

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...

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...

Executive Order 14210 issued by the Trump Administration calls for a "critical transformation of the Federal bureaucracy," which provides, among other things, submission of a plan by the Director of the Office of Management and Budget (OMB)...

A limited liability company (LLC) can be taxed as an S corporation, but an S corporation is not always a good choice. Learn the tax options available to LLCs and the advantages and disadvantages of electing to be taxed as an S corporation. When evaluating...

The U.S. branch profits tax (BPT) is a critical component of the federal tax system, ensuring foreign corporations with U.S. branches face a tax burden similar to U.S.-incorporated subsidiaries. Imposed at a 30% rate on the "dividend equivalent amount...

Virtually every state has some type of franchise tax or fee that is imposed on domestic and/or foreign corporations as part of the cost of doing business in the state. The measure of franchise taxes varies from state to state. While some franchise taxes...

A business entity that is treated as a disregarded entity for tax purposes is generally ignored for U.S. federal income tax purposes even though it is a separate legal entity for state law purposes. While disregarded entities offer significant advantages...

For tax practitioners, understanding tariffs is one of the keys to unlocking the complexities of international trade. Tariffs not only shape the cost structure of imported goods but also ripple through pricing strategies, supply chain decisions, and overall...