With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the significant changes to the Tax Code the Administration won’t find easy to navigate through a Congress that features the slimmest of majorities. Major revisions to the Tax Cuts and Jobs Act of 2017Tighter rein on interest deductions and inversionsRepealing BEAT and FDII, creating a … [Continue reading] about The Other Green Book: Treasury Explains Administration’s Tax Proposals
Supreme Court–Appointed Special Master Applies Place-of-Purchase Jurisdictional Rule to MoneyGram’s Unclaimed “Official Checks”
Our Unclaimed Property Team reviews the report of the U.S. Supreme Court’s Special Master parsing the definitions of “money orders” and “similar instruments” and how those words decide if certain unclaimed property falls under federal common law or … [Continue reading] about Supreme Court–Appointed Special Master Applies Place-of-Purchase Jurisdictional Rule to MoneyGram’s Unclaimed “Official Checks”
Taxpayers Can Strike First: Supreme Court Allows Pre-Enforcement Challenges to Certain IRS Regulatory Actions
Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action. CIS Services v. IRS narrows the reach of the Anti-Injunction ActThree … [Continue reading] about Taxpayers Can Strike First: Supreme Court Allows Pre-Enforcement Challenges to Certain IRS Regulatory Actions
Check Your Timing: Tax Traps for the Unwary in Acquisition Agreements
Even one day of unanticipated tax liabilities can have meaningful consequences. Our Federal Tax Group turns your attention to the little-regarded – but still important – straddle-period provisions in acquisition agreements. The “interim closing of … [Continue reading] about Check Your Timing: Tax Traps for the Unwary in Acquisition Agreements
Bracing for the Next Wave of Delaware Unclaimed Property Reform: Review of SB 103 and SB 104
Our Unclaimed Property Team examines a pair of fast-tracked Delaware bills that would reform a swath of the state’s escheat laws in response to ongoing litigation and other disputes over audits and voluntary disclosure agreements. Defining, … [Continue reading] about Bracing for the Next Wave of Delaware Unclaimed Property Reform: Review of SB 103 and SB 104