United States: Tax Authorities

Senator Thom Tillis introduced a bill (called the "Tackling Predatory Litigation Funding Act") that would impose additional significant taxes on litigation funding investments.

On May 22, 2025, the US House of Representatives passed a bill that includes tax increases on certain foreign persons to target purported unfair taxes imposed by foreign countries.

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

The June 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate.

On May 22, 2025, the U.S. House of Representatives passed "The One Big, Beautiful Bill," a comprehensive tax reform package aimed at reforming the U.S. tax code.

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...

Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the "Code"), excludes "the distributive share of any item of income or loss of a limited partner, as such" from earnings subject to U.S. federal self-employment tax ("SECA").

The research and development (R&D) tax credit offers substantial tax savings for businesses conducting innovative research. It supports technological progress by reducing tax liability...

On April 28, YA Global Investments, LP ("YA Global") filed an appeal in the 3rd Circuit, contesting the Tax Court's decision in YA Global Investments, LP v. Commissioner, which we discussed here and here.

In this new trade landscape, it is more important than ever to coordinate customs and operational planning with income taxes and transfer pricing.

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