Corporate Alternative Minimum Tax (CAMT): Impact on Private Equity

The Alternative Minimum Tax (AMT) was introduced in the United States in 1969 to ensure that high-income taxpayers contributed a minimum amount of tax, thereby precluding them from significantly reducing or eliminating their tax liability through the regular tax system. Similarly, the Corporate Alternative Minimum Tax (CAMT) was first instituted under the Tax Reform Act […]

Digital & Cloud Transactions: Treasury & IRS issue final regulations on digital content and propose cloud transaction sourcing rules

The Treasury and the IRS have issued final regulations under Section 861 (the “2025 final regulations”), addressing transactions involving “digital content” and certain “cloud transactions.” For these purposes: These regulations primarily affect taxpayers involved in digital content or cloud transactions. They will take effect for taxable years beginning on or after their publication date in […]

“Limited Partner” exception to Self-Employment Tax under IRC Section 1402(a)(13)

On December 23, 2024, the Tax Court reaffirmed its interpretation of the “limited partner exception” to self-employment tax under section 1402(a)(13) of the Internal Revenue Code in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114). This decision echoes its earlier ruling in Soroban Capital Partners LP v. Commissioner (161 T.C. No. 12) and has […]

End to U.S. Citizenship Based Taxation – A Possibility?

On December 18, 2024, Representative Darin LaHood, a member of the House Committee on Ways and Means, introduced the Residence-Based Taxation for Americans Abroad Act, a bill that would implement a residence-based taxation system for U.S. citizens currently living overseas. The legislation seeks to transition from the current citizenship-based taxation system to a residence-based taxation […]

2024 Presidential Election & Tax Policy – Comparative Analysis

As the November elections approach, tax policy has emerged as a critical issue for American businesses. The 2017 Tax Cuts and Jobs Act (“TCJA”), enacted during Former President Donald Trump’s presidency, includes several provisions set to expire in 2025, making tax proposals from both candidates particularly relevant. While the policies of Vice President Kamala Harris […]

Italy doubles its”flat-tax”to €200,000

On Wednesday, August 7, 2024, Italian government approved a measure that increases the “flat-tax” imposed on individuals who elect to be part of the regime and obtain tax residency in Italy. The decree doubles the existing 100,000 euros flat-tax to 200,000 euros (approximately $218,000) per year. The “flat-tax” regime in essence is a cap on […]

U.S. and Switzerland Sign New FATCA Agreement

July 1, 2024 U.S. and Switzerland executed a new intergovernmental agreement (“IGA”) to implement the U.S. Foreign Account Tax Compliance Act (“FATCA”) on June 27, 2024, in Bern, Switzerland. The new Model 1 IGA, to come into effect starting 2027, provides for the reciprocal automatic exchange of information, addresses legal impediments, reduces burdens for Swiss […]