Business Organization Tax

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IRS Private Letter Ruling Provides Tax Planning Opportunities for Healthcare Companies

The IRS recently issued PLR 201451009, providing that a management services company and two professional corporations (PCs) were members of the same affiliated group under Section 1504(a) of the Internal Revenue Code...more

Premium Reimbursement Arrangements Get Relief - More ACA Transition Relief—This Time for Small Employers and S-Corps

The IRS issued guidance on Feb. 18, 2015, providing temporary relief until June 30, 2015, from steep penalties for small employers and S-corps that have continued to use premium reimbursement arrangements to provide health...more

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect...more

Succession planning for the family-owned hospitality business

Succession planning for the family-owned hospitality business: protecting your family and your business - The hospitality industry has been kind to families over the centuries, providing a good living for many, and...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

IRS Ruling Permits Inclusion of “Friendly PCs” in Consolidated Federal Income Tax Returns

On December 19, 2014, the Internal Revenue Service (“IRS”) issued a private letter ruling (the “Ruling”) allowing corporations that manage physician practices through a so-called “friendly physician” arrangement to treat the...more

I Received a Notice from the IRS – Now What?

Don’t panic! You aren’t going to jail. However, you don’t want to ignore it. The issue will not go away on its own. A prompt response to the notice will save you a major headache later on....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

IRS Simplifies Accounting Method Changes Under “Repair Regs”

In new Rev. Proc. 2015-20, the IRS permits a “small business taxpayer” to use a simplified procedure to change its method of accounting under the final tangible property regulations for tax years beginning on or after January...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

California Tax Developments - A Reed Smith Quarterly Update (4th Quarter 2014)

Case Updates - California Supreme Court Accepts Review of Documentary Transfer Tax Case In our last quarterly update, we reported on a controversial opinion recently published by a California Court of Appeal. In 926...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

Tax Policy Update

NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance...more

Private Equity Tax Alert - What might the General Election bring

As we enter the run-up to the General Election in May, private equity funds and their managers might want to consider what the possible tax implications of a new Government might be both for the managers of their portfolio...more

‘Horizon scanning’: is a ‘Top-Level’ Firm Required to See Further?

This case involved allegations of professional negligence in the context of tax planning advice, and saw the application of reasonably familiar principles. Whilst these cases always depend on their facts, the decision may...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

New York State ALJ Determines Travel Reservation Facilitation Receipts and Online Advertising Receipts Constitute Service Receipts...

There has been significant controversy in New York regarding whether receipts from services—particularly those that may be delivered via the Internet—constitute “service” receipts or “other business receipts” for corporate...more

Inside the New York Budget Bill: Proposed Sales Tax Amendments

Governor Andrew Cuomo’s 2015–2016 New York State Executive Budget Bill proposes several significant changes to New York’s sales and use tax statutes. Several of these changes, while touted by Governor Cuomo as “closing...more

State and Local Taxation: Headline News and Trends

In This Presentation: - Megatrends and Developments - Business Activity Taxes - Transaction Taxes - Other Issues - Excerpt from Megatrends and Developments: PRIVATE LAWSUITS. CHOOSE...more

Locke Lord QuickStudy: The Fate of Partnerships Under President Obama’s 2016 Proposed Budget

On Monday, February 2, President Obama formally released his 2016 budget proposal and, as expected, it contained numerous changes to the Internal Revenue Code. ...more

Taxes in Qatar

How favorable is the tax regime in Qatar? - The most favorable in the world, according to the 2009 Forbes Tax Misery and Reform Index, which ranked countries in terms of the harshness of their tax regimes. The index...more

Cash Based Business? Have Good Books and Records

What happens when a taxpayer operates a cash based business and lacks adequate books and records according to the IRS? The IRS can use any reasonable method to reconstruct the taxpayers income and expenses. (See, Estate of...more

California Supreme Court to Review Controversial Documentary Transfer Tax Case

The California Court of Appeal recently held, in 926 North Ardmore Avenue v. County of Los Angeles, that a documentary transfer tax is triggered when a transfer of an interest in a business entity that owns real property...more

Marketing and Management Tips For Retirement Plan Providers

I have been very lucky in my career. It has nothing to do with intelligence or good looks or being pushed by the right people. I‘ve been lucky because I’ve been able to reinvent myself and some- times turn lemons into...more

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