The One Big Beautiful Bill Act, enacted as Public Law 119-21 on July 4, 2025, introduces new section 4475,i which imposes a 1% excise tax on remittance transfers made after December 31, 2025. The provision was initially touted as one that “Makes America Win Again,” because it would affect only certain immigrants. As enacted, however, the excise tax applies equally to all individual taxpayers, whether US citizen, resident, or immigrant. It is unclear just how…
On July 4, President Trump signed the ‘One Big Beautiful Bill Act’ into law, including provisions reducing federal income tax on qualified tips and overtime compensation. For employers, the new law raises a host of practical questions: In this video chat, our Employment & Compensation and Tax partners unpack this significant development in federal tax policy. Tune in to discover what these changes may mean for your operations, and for practical tips to navigate the new law.…
Overview We reported in May on the provisions in the House’s One Big Beautiful Bill addressing two of President Trump’s campaign promises – no taxation of tips and overtime. The Senate has now passed its version of the One Big Beautiful Bill, which includes its version of these provisions in sections 70201 and 70202. See our prior blog post here for a detailed discussion of the House provisions. While the basic structure of the provisions…
Overview Above-the-line deductions for qualified tips and qualified overtime While we do not often report on proposed legislation, two provisions in the bill the House Ways and Means voted out of Committee on May 14th (and which was voted out of the House Budget Committee on May 18th) are worthy of attention, as they reflect how two of President Trump’s campaign promises are beginning to take shape. Sections 110101 and 110102 of the Ways and Means…
News headlines reinforce what every business knows – that there are business reasons for providing security to C-suite executives. Those executives are seen as the face of the company and often bear the brunt of the public’s gripes against a company. Prominent business leaders, such as business executives, are often the targets of threats due to their affiliation with the company and are in need of protection as a result. Ensuring their safety is often…
Earlier this year, the Internal Revenue Service (“IRS”) announced it would be using advanced analytic techniques and additional funding to audit tax compliance by businesses when their business aircraft are used for personal reasons by executives. The IRS’s Large Business and International Division also added a “Business Aircraft Campaign” to its list of compliance campaigns. This focus by the IRS appears to have triggered calls for it to revisit the manner in which personal use…
On April 12, 2024, Treasury and the IRS published proposed regulations on the 1% excise tax imposed by Internal Revenue Code Section 4501 on the value of stock repurchased by a US public corporation or a 50% affiliate. The proposed regulations elaborate on and clarify compensation-related issues that arose in Notice 2023-2, December 27, 2022 (addressed in our prior blog post), including: For a full discussion of these topics and practical tips on next steps, we…
On August 16, 2022, President Biden signed the Inflation Reduction Act (“IRA”) into law. One of the new provisions the IRA introduced is the stock buyback excise tax under Code section 4501, which applies as of January 1, 2023 and was designed to target large corporations that implement stock buybacks. Background Code section 4501 imposes a 1% excise tax on the value of covered corporation stock that is repurchased by the covered corporation or a…
After months of partisan bickering and Senate inaction, Congress finally passed another round of COVID-19 relief legislation as part of the Consolidated Appropriations Act, 2021, P.L. 116-260, (“CAA”), which was signed into law on December 27, 2020. We provide a summary of the tax-related CAA provisions and key modifications to the Paycheck Protection Program (“PPP”), before discussing President Biden’s tax agenda for 2021. The CAA’s tax provisions focus primarily on providing economic relief to taxpayers…
In an apparent follow-up to its General Legal Advice Memorandum dated May 18, 2020 (GLAM 2020-004), the IRS has issued an internal procedural update that (1) extends the application of the administrative waiver of late employment tax deposit penalties for stock options to stock-settled restricted stock units (“RSUs”) and stock appreciation rights (“SARs”) and (2) shortens the waiver’s deposit period by one day to align with current SEC securities open-market transaction settlement rules. The internal…