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24 Months Through the Crystal Ball: Emerging Trends in State and Local Taxation (Part I)

For businesses operating across state lines, state taxation bears a resemblance to standing with one foot on each of two logs in a flowing river: even during calm periods, staying above water is a challenge. And these are not...more

Domestic International Sales Corporations—A Tax Saving Tool for U.S. Companies

Does your business earn income from making and exporting goods, such as agricultural products, apparel or software? If so, in connection with such exports, does your company use a “domestic international sales corporation,”...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

Department of Revenue releases detailed guidance for corporate excise tax amnesty program

The Massachusetts Department of Revenue released TIR 15-2 specifying the administrative details of the amnesty program authorized by the legislature earlier this year. The amnesty period is open now through May 15, 2015, for...more

Stock and Asset Sales: Tax Consequences of Each Transaction

As discussed in prior posts, an asset sale transfers only the assets of the business, whereas a stock sale transfers some or all of the ownership interest in the business as well as its obligations and liabilities....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

Nevada Business License Fee Proposal Could Impact Employers

Nevada employers should pay close attention to a tax bill currently under consideration by the Nevada Legislature. Senate bill 252 includes a new business license fee proposal that bases its fees scale on gross revenue and...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

IRS Proposes Curtailing “Next-Day Rule” in Corporate Acquisitions

Are you a day late? - On March 5, the Internal Revenue Service (the IRS) published proposed regulations (REG-100400-14, RIN 1545-BM14) (the Proposed Regulations) that would place strict new guidelines on the “next-day...more

Southeast State & Local Tax: Important Developments - March 2015

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast....more

[Webinar] Formation Issues and Changes in Structure: Tax Considerations - Mar. 19, 12-1PM PST

Please join Sheppard Mullin for our monthly Third Thursday Emerging Company Webinar Series educating entrepreneurs and emerging companies on the key legal issues they face during the growth of their companies. These...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

M&A Update: Market Pressures, Favorable Law Spur REIT Conversions and Spinoffs

Urged on by activists and institutional shareholders, a large number of companies with real estate holdings pursued real estate investment trust (REIT) conversions or spinoffs in 2014. At least half a dozen companies...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

1031 exchange: a business strategy to defer capital gains tax, P.2

In our last post, we began speaking about the potential for businesses to take advantage of tax law to defer capital gains tax on business property they want to relinquish. One important thing to point out, though, is that...more

Alabama Legislator Introduces Broad Unitary Combined Reporting Bill

As part of Republican Governor Robert Bentley’s eight-bill revenue package, Representative Mike Hill (R-Columbiana) has introduced a mandatory unitary combined reporting bill (often called “MUCR”), H.B. 142, that would be...more

IRS Reviewing Fewer Business Returns

The IRS announced yesterday that it examined 6 percent fewer tax returns in 2014 than 2013. In addition, the total number of tax exams for business returns has dropped to the lowest level in eight years. For large...more

Distressed Energy Sector Creates Need for Thoughtful Tax Planning

How do tax issues change for energy companies in a distressed environment? KS: Companies in a distressed environment often generate substantial losses which may need to be funded with additional debt or equity...more

Article Abstract – Preferred Interest Partnerships to Use DSUE Amounts Received by a Surviving Spouse

These abstracts are provided as a service to the readers of Rubin on Tax to advise them of articles that may be of interest to them, both as they are published and as a research tool...more

Recent U.S. Tax Developments Affecting Publicly Traded Partnerships

Partnerships targeted to widespread investors are a popular investment vehicle and a significant source of funding for oil and gas projects. However, their use is affected by the publicly traded partnership (“PTP”) tax rules....more

Abandon All Hope? If a Partnership, Maybe

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

Recent Developments - Australian Transfer Pricing (TP) Rules: Time To Step Up

With the Australian Taxation Office's (ATO) escalating focus on international profit shifting, it is essential for multinational taxpayers (MNEs) to properly understand the new Australian Transfer Pricing (TP) rules, assess...more

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