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Counsel Stephen Josey will moderate a panel at the NYU Tax Controversy Forum titled “Cross Border Information Gathering and Discovery” at 3:20pm ET on Thursday, June 26 in New York.

On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”).

In the afternoon of June 16, 2025, the Senate Finance Committee (“SFC”) released its proposed legislative text of the tax title for the “One Big Beautiful Bill,” H.R. Con. Res. 14, 119th Cong. (2025) (the “Reconciliation Bill”).

Not long after starting his second term, U.S. President Donald J. Trump announced tariffs on numerous imports from some of the nation’s major trading counterparties, with tariff amounts varying depending on the country and commodity type.

Lawmakers have been making their lists and checking them twice, and soon we will find out who’s been naughty or nice.

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act (“IRA”).

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act.

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act (“IRA”).

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act (“IRA”).

On September 12, 2024, the Department of the Treasury and the Internal Revenue Service issued long-awaited proposed regulations (the “Proposed Regulations”) on the application of the corporate alternative minimum tax, which imposes a 15% corporate alternative minimum tax on the adjusted financial statement income (“AFSI”) of certain large corporations for tax years beginning after December 31, 2022.

Partner Chris Mangin, with assistance from Partner Paige Anderson, led the ABA Section of Taxation’s comment letter (the “Comments”) on Treasury and the IRS’s recently proposed regulations under Sections 897 and 892 (the “Proposed Regulations”) regarding issues affecting foreign investment in U.S. real estate.

Just eight weeks after former Chancellor Kwasi Kwarteng unexpectedly announced the largest package of tax cuts implemented in the UK since the 1970s, the UK Government has now effectively gone into full reverse following new Chancellor Jeremy Hunt’s Autumn Statement, delivered on 17 November 2022, in which he announced a £55 billion combined package of tax rises and spending cuts intended to shore up the UK’s public finances.