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Business Organization Tax

Read Business Organization updates, alerts, news, and legal analysis from leading lawyers and law firms:

Tax court finds self-employment tax for active LLC member

by Thompson Coburn LLP on

Self-employment (SE) tax is one of the driving forces when a tax advisor recommends what type of entity to use for one’s business. My previous post, “Tax court finds no self-employment tax for passive LLC member,” described...more

Did A Non-Existent Committee Move To Update Corporations Code?

by Allen Matkins on

In April, I kvetched about numerous outdated references in the California Corporations Code. For example, several provisions of the Code continue to refer to the “Internal Revenue Code of 1954” more than three decades after...more

Using Your Payroll Provider As Your 401(k) TPA Is A Big Mistake

by Ary Rosenbaum on

Like beating a dead horse, I will again say that it is a bad idea for plan sponsors to hire their payroll provider as their 401(k) third party administrator (TPA)....more

The Netherlands proposes changes to dividend withholding tax

by DLA Piper on

The Dutch government has released an attractive proposal to fully exempt withholding tax on dividends paid to non-resident shareholders in treaty countries provided certain conditions are met. Many multinational enterprises...more

ESOP Trends in the Marketplace

by McDermott Will & Emery on

Over the years, employee stock ownership plans (ESOP) have evolved in many ways. Currently, ESOP transactions began to resemble traditional M&A transactions including financial structures, warrants and market rate sub-debt....more

IRS Issues New Rules for Management Contracts involving Tax-Exempt Financed Facilities

by Miller Canfield on

The Internal Revenue Service (IRS) issued Revenue Procedure 2017-13 (Rev. Proc. 2017-13) on Jan. 17, 2017. The procedure provides more flexible, modern rules for structuring management contracts involving tax-exempt financed...more

Transfer pricing compliance in Russia. Part 3. Stages of transfer pricing compliance

by Dentons on

Dentons’ Tax and Customs practice congratulates its clients and friends on the end of the first stage of transfer pricing compliance for 2016 – the filing of the notification of controlled transactions completed in 2016!...more

Podcast - Shrink the Section 457A Tax on Hedge Fund Management and Incentive Fees and Expand Your Impact

by Ropes & Gray LLP on

In a recently released Ropes & Gray podcast, asset management partner Isabel Dische, tax partner Brett Robbins, and private client partner Cameron Casey discuss the effect of Section 457A on pre-2009 management and incentive...more

Senate Bill Proposes Major Market-Based Remodel of Cap-and-Trade Program

by Stoel Rives LLP on

California’s cap-and-trade program withstood a battle in court, and now the Legislature is proposing changes to the controversial program. Senator Bob Wieckowski (Democrat – District 10), Chair of the Environmental Quality...more

Manufacturing Matters May 2017

by DLA Piper on

As mentioned in the last issue of Manufacturing Matters, “Smart Manufacturing”, including automation, is gaining momentum. A number of leading global manufacturers have already adopted it, and according to The Annual...more

Limitation of Corporate Loss Carryforward Affecting Only Particular Share Transfers Declared Unconstitutional

by White & Case LLP on

The Federal Constitutional Court of Germany held that the forfeiture of tax loss carryforwards under Sec. 8c para. 1 sent. 1 CITA is inconsistent with the principle of equal treatment pursuant to German Constitutional Law....more

A Step in the Right Direction: IRS Rules on North-South Spinoffs

The Internal Revenue Service (IRS) recently released guidance on certain “north-south” spinoff transactions. Generally, a “north-south” transaction consists of a transfer of property from a shareholder to a corporation close...more

Guidance For North-South Spinoffs

by Farrell Fritz, P.C. on

The IRS continues to issue guidance in the much debated area of corporate spinoffs. A recently published ruling examined the federal income tax treatment of the two steps that comprise a so-called “north-south” transaction.”...more

Update on US Federal Tax Reform Proposals and Their Effect on the Renewable Energy Industry

by Shearman & Sterling LLP on

While tax reform has been a stated focus of the Trump administration and Congress, details remain elusive. The administration has recently reaffirmed its desire to enact comprehensive corporate and individual tax reform, but...more

All Partnerships Need to Adapt to the New Partnership Audit Rules Now

by Hinshaw & Culbertson LLP on

Historically, partnerships and multiple-member limited liability companies ("LLCs") taxed as partnerships generally have not had to pay income taxes at the partnership level. As a result of federal tax law changes effective...more

Simple Advice to Retirement Plan Sponsors

by Ary Rosenbaum on

I don’t know about you, most of the advice I got growing up was usually wrong. Maybe some very unsuccessful people surrounded me when I was younger, but advice can be biased and self-serving at times. The best advice I would...more

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

German Constitutional Court Declares Parts of Provisions Regarding Forfeiture of Tax Losses and Loss Carry Forwards...

by Shearman & Sterling LLP on

The German Constitutional Court held in its decision dated 29 March 2017 (published on 12 May 2017) Section 8c sentence 1 German Corporate Income Tax Act (KStG) (introduced in 2008 and replaced by the identical provision of...more

Tax administrations prepare for automatic exchange of CbC reports - are you ready? Three takeaways

by DLA Piper on

OECD announced that another important step has been taken to implement country-by-country (CbC) reporting requirements, as signatories to the Multilateral Competent Authority Agreement on the Exchange of CbC Reports (the CbC...more

IRS Issues Guidance on “North-South” Transactions

by Proskauer - Tax Talks on

On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the “Ruling”), which helpfully clarifies that the separate steps of a typical “north-south” spinoff transaction will be respected, and announced...more

Viewpoints - Issue 28 - The Board’s Role in Overseeing Innovation

by King & Spalding on

Innovation has become an essential capability for any large public company if it wants to remain competitive. With some studies suggesting that 50% of the companies in the S&P 500 list could be replaced over the next 10...more

Succession Planning—Bet the Farm on It

by Ward and Smith, P.A. on

Despite recent trends toward consolidation in the agricultural industry, farming generally remains a family affair. According to the United States Department of Agriculture, 97 percent of all farms in the United States are...more

Corporate and Financial Weekly Digest - Volume XII, Issue 18

SEC/CORPORATE - US District Court Holds That Discretionary Tax Withholding is Exempt Under 16b-3 - Several companies have received shareholder letters seeking to recover short-swing profits from insiders under Section...more

It’s time for Profit Sharing Payment in Mexico!

As provided by the Mexican Federal Constitution and the Federal Labor Law (FLL), employees are entitled to receive profit participation on their employer’s profits every fiscal year. Ten percent of the company’s taxable...more

Small 401(k) Plans Have Bigger Problems Than Larger Plans

by Ary Rosenbaum on

Common sense would make you think that larger 401(k) plans would have the larger problems. Sometimes common sense and reality are mutually exclusive. Thanks to the quirks of the retirement plan business and how it prices...more

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