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A Good Retirement Plan Doesn’t Grow On Trees

It doesn’t grow on trees, it’s not in the water, and it doesn’t happen by accident. It didn’t happen overnight, it didn’t happen in a vacuum, and it certainly didn’t come out of thin air. A good retirement plan takes a lot of...more

Australian Tax Alert - Investment Manager Regime (IMR) – Draft Legislation To Implement Element 3 Finally Released

The exposure draft (ED) legislation removes tax impediments for foreign investors investing into Australia in order to attract foreign investment and promote the use of Australian fund managers. OVERVIEW - The...more

UK budget 2015

Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation....more

European Commission Unveils Tax Transparency Package

The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national corporations. As of next year, EU members would have to declare their...more

Ship on course but choppy waters abound! UK Budget 2015: 10 key measures impacting business

Before the Budget was announced, there was natural apprehension that, given the impending general election, the Chancellor would pander to the electorate and sail off course from this Government’s carefully navigated path...more

Massachusetts Unveils Limited Amnesty Program

Beginning March 16, 2015, the Massachusetts Department of Revenue is offering an aptly described “limited” amnesty program for taxpayers with certain tax liabilities. Technical Information Release 15-2....more

Another 10 Wrong Ideas That Plan Sponsors Have About Their Retirement Plans

Most of the time, sequels suck. Except for perhaps Terminator 2 and The Godfather Part II, most sequels are like such bombs as Caddyshack II and Beyond the Poseidon Adventure. Despite this dislike of sequels, giving Plan...more

Investment Funds Update - Europe: Key legal and regulatory updates for the funds industry from the primary European asset...

Federal Ministry of Finance Guidance on Tax for Closed-Ended AIFs - The Federal Ministry of Finance has issued guidance on 12 February 2015 that broadens the favorable tax regime for investment partnerships applicable to...more

Companies Should Monitor Deferred Compensation Arrangements For Section 409A Compliance Purposes

Given the complexity of the rules under Section 409A of the Internal Revenue Code, which govern the timing and taxation of payments made under non-qualified deferred compensation arrangements (NDCAs), companies are encouraged...more

The Top 10 Wrong Ideas That Plan Sponsors Have About Their Retirement Plans

People can get the wrong idea at times. I’ll never understand what Fred Silverman was thinking when he made Jean Doumanian the successor to Lorne Michaels as Executive Producer of Saturday Night Live or when he imported Pink...more

Tax Policy Update

NUMBER OF THE WEEK: 8 percent. The increase in the total amount of corporate profits kept abroad, according to the latest analysis of securities filings by Bloomberg News. The report confirms what U.S. companies have as much...more

Year Long Pause Lifted on MLP Qualifying Income Private Letter Rulings – Proposed Regulations to be Issued

Following a year long pause, the IRS announced Friday that it has resumed its review of pending private letter ruling (PLR) requests and is accepting new PLR requests concerning MLP qualifying income under Section...more

Massachusetts Tax Developments - A Reed Smith Quarterly Update: March 2015

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look at the most recent developments in Massachusetts corporate tax, sales and use tax, and tax administration; and discuss some...more

Overview of the Taxation of Foreign Currency

In this Newsletter: - Determination of the Functional Currency and Definition of a “QBU” - Section 988 — Non Functional Currency Transactions - Section 986 — Translation Rules for Earnings and Profits and...more

Human Emotional Mistakes A Retirement Plan Provider Should Avoid

We are all human unless someone of us are cyborgs sent by Cyberdyne Systems in the future. Seriously, humans are controlled by emotions and everyone knows that after going through their teenage years. Human emotion can make...more

Congressional Proposals for Nonprofit Tax Breaks and Extenders

In February, the House of Representatives passed several tax bills and the Senate Finance Committee approved several tax bills that, if ultimately enacted, would impact tax-exempt organizations....more

It’s The Plan Sponsor’s Responsibility, Just Because

I have been a fan of Sesame Street since I was a child and again as an adult when my children were younger. It’s a brilliant show that has educated millions of kids in the past 45 years. One of the great events in Sesame...more

Real Estate Acquisitions in Japan

Interest in acquiring Japanese real estate, such as hotels, office buildings and retail complexes, is increasing due to Abenomics and the depreciation of the yen against major currencies. Japan expects to have a robust estate...more

Abandonment Losses Back on the Table!

Several years ago, many taxpayers faced with underwater partnerships would abandon their partnership interests, thereby triggering an ordinary loss. This ordinary loss was often preferred over the capital loss that would be...more

Morrison & Foerster Quarterly News Tax Talk - Volume 7, No.4 January 2015

In This Issue: - Congress Passes Year-End Tax Extenders Bill - House Adopts New “Dynamic Scoring” Rule - Foreign Fund Engaged in Lending and Stock Distribution Not Protected by “Trading in Stock or Securities”...more

FASB Eliminates Extraordinary Items Reporting

In January, the FASB adopted a final Accounting Standards Update that eliminates the requirement that preparers report events that meet the criteria for extraordinary classification separately in an income statement, net of...more

Reasons When Plan Sponsors Should Change Their Plan Providers

People are afraid of change and sometimes; change can be a good thing. Change for the sake of change isn’t a good idea and there are times when change is absolutely necessary. This article is about when it’s probably a good...more

Favorable German tax regime for partnership-type AIFs expanded

The German Federal Ministry of Finance has recently issued guidance that broadens the favorable tax regime for investment partnerships applicable to closed-end alternative investment funds (AIFs). The following Dechert...more

ALJ: New York NOL Deduction Does Not Apply When Tax Is Not Paid on Income Base

A New York State Division of Tax Appeals administrative law judge (ALJ) recently determined that a banking corporation was not required to hypothetically use a net operating loss (NOL) deduction to decrease its entire net...more

What Retirement Plan Sponsors Have To Fear

In his inauguration speech, Franklin Delano Roosevelt said that “the only thing we have to fear is fear itself.” Retirement plan sponsors have more to fear than fear itself except the problem is that they’re unaware that they...more

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