Holland & Knight LLP
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- Miami701 Brickell Avenue Suite 3300 , Miami, Florida, USA, FL 33131
- Web: www.hklaw.com
- View ranked office
- Mexico CityPaseo de las Palmas No. 405, Suite 504, Col. Lomas de Chapultepec, Miguel Hidalgo, Mexico City, Ciudad de México, Mexico, 11000View ranked officeMexico CityPaseo de la Reforma No. 342 Piso 28, Col. Juárez, Del. Cuauhtémoc, Mexico City, Ciudad de México, Mexico, 06600View ranked officeMonterreyRicardo Margáin No. 335, Torre II, Piso 2 Col. Valle del Campestre San Pedro Garza García, N.L. , Monterrey, Nuevo Leon, Mexico, 66265View ranked office
- Atlanta1180 West Peachtree Street, One Atlantic Center, Suite 1800, Atlanta, Georgia, USA, GA 30309View ranked officeWashington, DC800 17th Street, NW, Suite 1100, Washington, DC, District of Columbia, USA, 20006View ranked office
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246 items provided by Holland & Knight LLP
Biden Administration's Made in America Tax Plan: Procedural Aspects
Part 1: Buckle Up for the Impact on International Tax Reform
Contract Allocations and Judicial Doctrines
District Court Case Applies Strong Proof Test to Boxing Contracts to Address Puerto Rico Source Income
Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework
Part 2: Buckle Up for the Impact on International Tax Reform
IRS Continues to Audit and Litigate Against Cannabis Businesses
As Congress continues to deliberate the federal legalization of marijuana, the cannabis industry continues to face scrutiny from the IRS under Section 280E of the Internal Revenue Code (Code).
Tax Liability Issues to Consider for High-Net-Worth Couples in Divorce
Divorce is not a topic most clients or tax advisors enjoy discussing.
Biden's American Families Plan Proposes Income Tax Hikes
The American Families Plan is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and the extension of tax cuts for families with children and American workers.
Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming
Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap1 in the U.S. may total $1 trillion per year.
Tennessee retains status as a leading trust jurisdiction
On May 12, 2021, Tennessee Governor Bill Lee signed into law a bill containing several revisions to Tennessee’s Uniform Trust Code (the “TN UTC”).
When IRS Penalty Assertions Are Unlawful
One of the most highly litigated issues in U.S. Tax Court is whether taxpayers are liable for certain penalties, additions to tax or additional amounts (each, a "penalty" and collectively, "penalties").
U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits
The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important victory to CIC and similarly situated taxpayers everywhere.
Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government.
Biden Administration's FY 2022 Budget and International Tax Changes
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy," June 3, 2021.)
The Green Book and Green Energy
Biden Administration's Budget Proposal Expands, Extends and Creates Tax Credits for Renewable Energy
Agreement on Global Tax Reform: What Happened and What's Next
Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the Base Erosion Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD)/G-20 Inclusive Framework (IF)1 since 2015.
How Can the Same Right Create 2 Separate Property Interests?
A Closer Look at Taxpayers' Property Rights, State Laws and the Legitimacy of IRS Liens/Levies
IRS Promotes Use of Fallback Language to Assist with Libor, IBOR Transition
The Internal Revenue Service (IRS) released Revenue Procedure 2020-44 to assist the market's transition from the London Interbank Offered Rate (Libor) and other interbank offered rates (IBORs) to alternative reference rates by promoting the adoption of fallback language recommended by the...
U.K., U.S. Reach Competent Authority Agreement on "Equivalent Beneficiary" Status
The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty).1
Offshore Lenders Targeted by IRS Audit Campaign
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of compliance risks to address taxpayer compliance.
IRS Extends Time Period of Telephonic Public Approval Hearings for Private Activity Bonds
The Internal Revenue Service (IRS) has released Revenue Procedure 2021-39, which extends the time period for telephonic Tax Equity and Fiscal Responsibility Act (TEFRA) hearings until March 31, 2022.
IRS Adds a Potential Self-Dealing Transaction to the No-Rule List
The IRS issued Revenue Procedure 2021-40, 2021-38 IRB 1 on Sept. 3, 2021, adding a private foundation issue to the list of those areas on which the IRS will no longer issue private letter rulings or determination letters: The IRS indicated that it is "currently reviewing" its prior ruling position..
Regulatory Changes Impact Leasehold Condominiums in New York
The leasehold condominium structure has become a popular way for landlords and nonprofit entities to establish or modify their relationship to permit space that the nonprofit would formerly lease to qualify for a real property tax exemption.
Regulatory Changes Impact Leasehold Condominiums in New York
The leasehold condominium structure has become a popular way for landlords and nonprofit entities to establish or modify their relationship to permit space that the nonprofit would formerly lease to qualify for a real property tax exemption.
NBAA Article Explains IRS Stance on Entertainment Disallowance for Sole Proprietors
The Internal Revenue Service (IRS) recently released Chief Counsel Advice (CCA) 2021-17-012 to explain that sole proprietor flights are generally not subject to the employer-provided aircraft rules in Internal Revenue Code Section 274
House Ways and Means Committee Tax Plan Proposes Changes to Estate Planning
The House Committee on Ways and Means has proposed a tax plan intended to fund President Joe Biden's "Build Back Better" $3.5 trillion infrastructure program.
Maintaining Privilege with Non-Lawyer Experts Under Kovel
Holland & Knight Partners Abbey Garber and Denise Mudigere, along with Associate Kate Minnich, co-authored an article in the December 2021 issue of Headnotes, a publication of the Dallas Bar Association.
Update for Employers: Recent Legislation Improves, Extends Employee Retention Credit
The Coronavirus Aid, Relief, and Economic Security (CARES) Act authorized a refundable tax credit important to many employers struggling as a result of the COVID-19 pandemic.
Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation
The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation.
Increased Hart-Scott-Rodino Thresholds Set to Take Effect Feb. 23, 2022
The Federal Trade Commission (FTC) has announced this year's revisions to the thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (HSR), which will apply to all transactions closing on or after Feb. 23, 2022.
IRS Issues Favorable Tax Regulations on Management Company Exception to FET
Over the past few years, the Internal Revenue Service (IRS) has worked to issue final regulations that provide guidance to aircraft management companies and aircraft owners regarding their federal excise tax (FET) obligations.
Proposed Regulations Greatly Expand Guidance on Required Minimum Distributions
The Internal Revenue Service (IRS) issued expansive proposed regulations (the Proposed Regulations) on Feb. 24, 2022, reflecting the required minimum distribution (RMD) rules as set out in the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019 and providing significant...
Biden Administration's Made in America Tax Plan: Procedural Aspects
Part 1: Buckle Up for the Impact on International Tax Reform
Contract Allocations and Judicial Doctrines
District Court Case Applies Strong Proof Test to Boxing Contracts to Address Puerto Rico Source Income
Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework
Part 2: Buckle Up for the Impact on International Tax Reform
IRS Continues to Audit and Litigate Against Cannabis Businesses
As Congress continues to deliberate the federal legalization of marijuana, the cannabis industry continues to face scrutiny from the IRS under Section 280E of the Internal Revenue Code (Code).
Tax Liability Issues to Consider for High-Net-Worth Couples in Divorce
Divorce is not a topic most clients or tax advisors enjoy discussing.
Biden's American Families Plan Proposes Income Tax Hikes
The American Families Plan is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and the extension of tax cuts for families with children and American workers.
Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming
Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap1 in the U.S. may total $1 trillion per year.
Tennessee retains status as a leading trust jurisdiction
On May 12, 2021, Tennessee Governor Bill Lee signed into law a bill containing several revisions to Tennessee’s Uniform Trust Code (the “TN UTC”).
When IRS Penalty Assertions Are Unlawful
One of the most highly litigated issues in U.S. Tax Court is whether taxpayers are liable for certain penalties, additions to tax or additional amounts (each, a "penalty" and collectively, "penalties").
U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits
The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important victory to CIC and similarly situated taxpayers everywhere.
Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government.
Biden Administration's FY 2022 Budget and International Tax Changes
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy," June 3, 2021.)
The Green Book and Green Energy
Biden Administration's Budget Proposal Expands, Extends and Creates Tax Credits for Renewable Energy
Agreement on Global Tax Reform: What Happened and What's Next
Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the Base Erosion Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD)/G-20 Inclusive Framework (IF)1 since 2015.
How Can the Same Right Create 2 Separate Property Interests?
A Closer Look at Taxpayers' Property Rights, State Laws and the Legitimacy of IRS Liens/Levies
IRS Promotes Use of Fallback Language to Assist with Libor, IBOR Transition
The Internal Revenue Service (IRS) released Revenue Procedure 2020-44 to assist the market's transition from the London Interbank Offered Rate (Libor) and other interbank offered rates (IBORs) to alternative reference rates by promoting the adoption of fallback language recommended by the...
U.K., U.S. Reach Competent Authority Agreement on "Equivalent Beneficiary" Status
The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty).1
Offshore Lenders Targeted by IRS Audit Campaign
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of compliance risks to address taxpayer compliance.
IRS Extends Time Period of Telephonic Public Approval Hearings for Private Activity Bonds
The Internal Revenue Service (IRS) has released Revenue Procedure 2021-39, which extends the time period for telephonic Tax Equity and Fiscal Responsibility Act (TEFRA) hearings until March 31, 2022.
IRS Adds a Potential Self-Dealing Transaction to the No-Rule List
The IRS issued Revenue Procedure 2021-40, 2021-38 IRB 1 on Sept. 3, 2021, adding a private foundation issue to the list of those areas on which the IRS will no longer issue private letter rulings or determination letters: The IRS indicated that it is "currently reviewing" its prior ruling position..
Regulatory Changes Impact Leasehold Condominiums in New York
The leasehold condominium structure has become a popular way for landlords and nonprofit entities to establish or modify their relationship to permit space that the nonprofit would formerly lease to qualify for a real property tax exemption.
Regulatory Changes Impact Leasehold Condominiums in New York
The leasehold condominium structure has become a popular way for landlords and nonprofit entities to establish or modify their relationship to permit space that the nonprofit would formerly lease to qualify for a real property tax exemption.
NBAA Article Explains IRS Stance on Entertainment Disallowance for Sole Proprietors
The Internal Revenue Service (IRS) recently released Chief Counsel Advice (CCA) 2021-17-012 to explain that sole proprietor flights are generally not subject to the employer-provided aircraft rules in Internal Revenue Code Section 274
House Ways and Means Committee Tax Plan Proposes Changes to Estate Planning
The House Committee on Ways and Means has proposed a tax plan intended to fund President Joe Biden's "Build Back Better" $3.5 trillion infrastructure program.
Maintaining Privilege with Non-Lawyer Experts Under Kovel
Holland & Knight Partners Abbey Garber and Denise Mudigere, along with Associate Kate Minnich, co-authored an article in the December 2021 issue of Headnotes, a publication of the Dallas Bar Association.
Update for Employers: Recent Legislation Improves, Extends Employee Retention Credit
The Coronavirus Aid, Relief, and Economic Security (CARES) Act authorized a refundable tax credit important to many employers struggling as a result of the COVID-19 pandemic.
Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation
The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation.
Increased Hart-Scott-Rodino Thresholds Set to Take Effect Feb. 23, 2022
The Federal Trade Commission (FTC) has announced this year's revisions to the thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (HSR), which will apply to all transactions closing on or after Feb. 23, 2022.
IRS Issues Favorable Tax Regulations on Management Company Exception to FET
Over the past few years, the Internal Revenue Service (IRS) has worked to issue final regulations that provide guidance to aircraft management companies and aircraft owners regarding their federal excise tax (FET) obligations.
Proposed Regulations Greatly Expand Guidance on Required Minimum Distributions
The Internal Revenue Service (IRS) issued expansive proposed regulations (the Proposed Regulations) on Feb. 24, 2022, reflecting the required minimum distribution (RMD) rules as set out in the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019 and providing significant...