Business Organization Tax

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Tax Court Affirms Use of Intergenerational Split-Dollar Arrangements

The Tax Court, in its decision earlier this month in Estate of Morrissette, examined intergenerational split-dollar arrangements between a mother's revocable trust and three irrevocable dynasty trusts, one established for...more

4 Takeaways from Council on Foundations 2016 Annual Conference

From April 9 to April 12, I had the good fortune to be part of the Council on Foundations 2016 Annual Conference. The Council welcomed nearly 1,400 leaders in the philanthropic sector to Washington, D.C., for plenary programs...more

Tax Review - April 2016

We are proud to present the next edition of our Tax Review which contains a selection of rulings and interpretations that were issued or published in March 2016. We hope that you will find in it information that may prove...more

New Examples of Program-Related Investments

The new examples describe additional charitable purposes and PRI terms and structures. On April 21, the Internal Revenue Service and Treasury Department issued final regulations regarding program-related investments...more

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

Program Related Investments: Final Regulations

Final Regulations Highlight the Broad Range of Available PRI Purposes, Recipients and Financial Structures - Final program related investment (PRI) regulations released and effective on April 25, 2016 illustrate the...more

Latin American countries focus on new legislation around tax and transfer pricing – independence limitations in Ecuador

A recent report published by the United Nations’ Economic Commission for Latin America and the Caribbean (CEPAL) calculated that Latin American countries have lost more than US$98 billion in tax revenues simply due to...more

Tax Newsletter - January / February 2016 (China & Hong Kong)

Welcome to the latest issue of our Tax newsletter. In this issue, we have covered a number of developments and cases in the PRC and Hong Kong which could impose legal and tax implications to your business. In the PRC,...more

New Regulations Expand Opportunities for Program-Related Investments

In recently released final regulations, the IRS and the Department of the Treasury have provided additional examples of investments that qualify as program-related investments (“PRIs”) for private foundations. The final...more

China's Nationwide VAT Reform - Implementation Rules Issued

In this issue, we have covered a number of developments and cases in the PRC and Hong Kong which could impose legal and tax implications to your business. In the PRC, there has been an important development in the past...more

Federal Court of Appeal Clarifies Test for “De Facto Control”

In McGillivray Restaurant Ltd. v. R., the Federal Court of Appeal (FCA) recently provided welcome news to the Canadian tax community concerning the appropriate legal test for determining whether a person has “de facto...more

[Event] Spring 2016 Tax Forum - May 12th, 8:00 am, Richmond, VA

Please join us for the Spring Tax Forum to be held at the Williams Mullen Center on Thursday, May 12, 2016. Topics Include: Contributions of Property to a Partnership: An Analysis of Section 704(c) Methods Part II:...more

M&A and 401(k): A Cautionary Tale

Mergers and acquisitions (M&A) are transactions in which the ownership of companies, other business organizations or their operating units are transferred or combined. It was also the name of a really boring class I took at...more

Estate of Clara M. Morrissette Secures Victory in Groundbreaking Estate Tax Case

In a case of first impression, the United States Tax Court ruled in favor of a taxpayer whose estate planning focused on the preservation and succession of a 70-year-old family-owned business. In Estate of Clara M....more

Singapore budget 2016

The Singapore Budget Statement 2016 (“Budget 2016”), delivered by Finance Minister Heng Swee Keat on 24 March 2016, has been described as balanced and transformative, focusing on both medium to long term restructuring (such...more

California Steps Up Criminal Tax Enforcement

California has a multi-agency task force known as the Revenue Recovery and Enforcement Team that was established to attack criminal tax evasion. The stated goals of the team are: (a) According to the State Board of...more

Foreign Financial Asset Reporting - Coming Soon to a Domestic Entity Near You

When Form 8938 reporting for foreign financial assets of U.S. taxpayers was first imposed a few years, only U.S. individuals were subject to it. The IRS has now issued final regulations that will commence reporting by...more

The Boomerang Effect and Tax Exempt Organizations

The Protecting Americans from Tax Hikes (“PATH”) Act of 2015, contained a provision by which tax-exempt organizations (a “TO”) could challenge revocation of exempt status by virtue of the filing of a declaratory judgment in...more

Breaking News: PRI Examples Are Finalized, with Improvements

Yesterday, Treasury and the Internal Revenue Service (IRS) finalized the regulations describing nine new program-related investment (PRI) examples that were first proposed on April 19, 2012. The final regulations incorporate...more

IRS Proposes Updates to Rules for Deemed Distributions of Stock and Stock Rights

On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more

MIDCO Transactions and the Expanding Universe of Transferee Liability

On April 20, 2016, partner Lawrence Hill (New York-Tax) presented a paper (co-authored with counsel Richard Nessler (New York-Tax)) titled “MIDCO Transactions and the Expanding Universe of Transferee Liability” to The Tax...more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

UK Budget 2016: Oil and Gas Taxation

Against the backdrop of higher development costs for aging oil and gas fields, depressed global oil prices and projections of slower global economic growth, the UK government announced significant tax cuts in its Budget 2016...more

PowerPoint Slides: Webinar on Recent Trends and Developments Affecting the IT Services and E-Commerce Sector Between the U.S. and...

Leading law firms Pepper Hamilton and Khaitan & Co. joined together on this webinar to discuss: • Start-Up India - India’s newly adopted regime for start-ups and what it means for foreign investors and IT and e-commerce...more

Video: Webinar on Recent Trends and Developments Affecting the IT Services and E-Commerce Sector Between the U.S. and India [Video]

Leading law firms Pepper Hamilton and Khaitan & Co. joined together on this webinar to discuss: • Start-Up India - India’s newly adopted regime for start-ups and what it means for foreign investors and IT and e-commerce...more

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