United States: Tax

Proposed Section 899, introduced as part of the "Defending American Jobs and Investment Act" (H.R. 591) and incorporated into the House Ways...

Under the proposed Defending American Jobs and Investment Act, introduced in the House of Representatives and approved by the House Ways and Means Committee on May 14, 2025, as part of the Trump administration's tax package known as "The One, Big, Beautiful Bill."

At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules...

Philanthropic giving has become an increasingly popular cornerstone to estate planning. Whether clients choose to give specific sums to charities during life or at death...

The United States imposes taxes and has legislatures and courts at the national, state and local levels. While there are a large number of taxes to consider, the taxes with which this chapter is predominantly concerned are income taxes and transfer taxes.

Whatever one may believe about climate change, there is no denying that there has been a series of natural disasters over the past decade. Most recent was the devastation of the January 2025 fires in Southern California.

On May 18, 2025, the House Budget Committee approved the legislation entitled, "The One, Big, Beautiful Bill" (the "House Bill").

In the recent United States Tax Court case O'Connor v. Commissioner of Internal Revenue, Judge Arbeit sanctioned the petitioner for advancing frivolous arguments contesting the authority of the IRS to assess tax.

Proposed Section 899, introduced as part of the "Defending American Jobs and Investment Act" (H.R. 591) and incorporated into the House Ways...

Riveron's M&A Tax and Transaction Services experts have observed the latest changes and evolving trends related to US trade and tariff policies and have participated in several discussions on the potential impacts.

The IRS has issued guidance endorsing a muscular approach to the application of "periodic adjustments" provisions. Those provisions authorize IRS adjustments of a taxpayer's pricing for transfers of high-value intangibles, including platform contribution transactions, for taxable years after the year of transfer, based on the actual, realized profitability of those intangibles in those later years

Federal courts next year are set to decide several cases that could shape how international tax planners will account for uncertainty and enforcement risks in 2025 and beyond.