United States: Tax

Bipartisan legislation aims to reduce compliance burdens on U.S. citizens living abroad by streamlining overlapping international financial reporting requirements and simplifying tax obligations.

In light of the recent article published by 9fin regarding the adverse implications to U.S. collateralized loan obligations ("CLOs") that resulted from U.K. withholding taxes imposed with respect to a certain dividend financing loan issued by the CFC Group, ...

In recent years, we have seen tax authorities increasingly relying on anti-abuse arguments to deny relief under double tax treaties.

A revocable living trust (sometimes called a revocable inter vivos trust) is a legal arrangement you create during your lifetime to hold legal title to your assets.

Estate planning isn't a one-time task—life changes like marriage, divorce, new children, real estate purchases, and shifts in net worth can all impact your plan's effectiveness.

As more families live, invest, and hold assets across multiple countries, estate plan ning increasingly requires coordination between legal systems that are not designed to work together.

Highly leveraged companies structured as partnerships face complex tax implications when restructuring debt obligations, particularly regarding cancellation of debt income.

This Snippet provides an overview of the impact of the Side-by-Side Safe Package for Pillar Two on US inbound structures, i.e. non‑US parented multinational groups with operations in the US.

This Snippet provides an overview of the impact of the Side-by-Side Safe Harbour for Pillar Two on joint ventures for US-parented multinational groups.

Selling an S corporation involves complex tax and legal considerations that can significantly impact after-tax proceeds. This comprehensive analysis examines stock sales versus asset sales, IRC Section 338(h)(10) elections, F reorganizations, and other transaction structures, revealing how different approaches affect both sellers and buyers through detailed tax modeling and strategic planning insights.

The One Big Beautiful Bill Act (OBBBA) has reshaped tax incentives for wineries, expanding opportunities for R&D expense deductions, production property depreciation, and energy credits. Understanding how these changes interact with winery operations—from fermentation systems to facility upgrades—can significantly impact cash flow and investment returns. This framework helps wineries align tax planning with operational decisions to maximize available benefits.

State and local tax (SALT) planning is entering a new phase of complexity. According to the BDO Tax Strategist Survey, over half of all audits and disputes stem from SALT issues. That's no surprise — state rules evolve rapidly...