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Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies
Feb 14, 2022
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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax regime. Importantly, while...
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Name/Image/Likeness Coming to Oregon K-12 Soon? Potential Impacts of the OSAA’s NIL Decision and Why Districts Need to Pay Attention Now
Feb 03, 2022
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The Oregon School Activities Association (OSAA) is set to consider language at its Feb. 7 meeting that could officially open the door to Oregon high school athletes profiting from Name Image Likeness (NIL) activities. An NIL activity is any business...
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Today in Tax: Financial Contract Modification and Foreign Tax Credits
Jan 19, 2022
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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Transition rules allow opportunity to avoid taxable income when modifying financial contracts from IBOR to another metric Contracts dependent on a discontinued in...
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Today in Tax: Eligibility of Electronic Services Income for FDII Deduction
Jan 12, 2022
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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation. In late 2017 the Tax Cuts and Jobs...
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Today in Tax: Foreign Account Reporting Requirements and Divisive Tax-Free Reorganizations
Dec 28, 2021
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Brief commentary on cases, rulings, notices, and related federal tax guidance as of December 29, 2021. FBAR Noncompliance Leads to More Severe Penalties in the 5th Circuit Penalties for FBAR violations can be severe if applied on a per-account basi...
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Today in Tax: Foreign Tax Credits Against Digital Service Taxes, Partial Spin-Off Structures, and Filing Relief for Equity Grants, Stock Sale Structuring, and Opportunity Zones
Dec 15, 2021
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Brief commentary on recent cases, rulings, notices, and related federal tax guidance as of December 14, 2021. U.S. Agreements Expand Potential Tax Credits for Digital Service Taxes The global tax landscape is rapidly changing as countries around th...
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