General Business Tax

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IRS Revokes Ruling That Imposed Excise Tax On Wholly Foreign Reinsurance Transactions

The Internal Revenue Service recently revoked a 2008 ruling that a 1% excise tax under section 4371(3) of the Internal Revenue Code applied to “reinsurance premiums paid by one foreign insurer or reinsurer to another.” The...more

EU Customs Developments: December 2015

EU Customs Policy - Union Customs Code Developments – Key Provisions Published - On 29 December 2015, the Implementing and Delegated Acts for the Union Customs Code (UCC) were published in the EU’s Official Journal...more

Partnership Audit Regime Shakeup

The recent Bipartisan Budget Act of 2015 (the “Act”) sets forth a new tax audit regime for partnerships (and limited liability companies taxed as partnerships) that will have far-reaching consequences. The new audit...more

Draft law: Russian VAT on software license transactions and e-commerce services

On 24 December 2015 a draft law was brought before the State Duma introducing important changes to the VAT taxation of software supply transactions and IT services ('Draft Law'). VAT on e-commerce services supplied to...more

Temporary Regulations Address Allocation of Creditable Foreign Tax Expense

The IRS published temporary and proposed regulations on allocations of creditable foreign tax expenditures (CFTEs).  The regulations make various technical changes to the existing regulatory safe harbor for allocating CFTEs. ...more

New IRS Audit Rules: Partnerships and LLCs Should Name A Partnership Representative For IRS Audits

New legislation will govern IRS audits of partnerships and LLCs for tax years beginning after December 31, 2017. The new rules will affect both existing LLCs and partnerships as well as new partnership and LLC agreements,...more

Recent Changes to the Tax Matters Partner Designation May Prove Costly to the Unwary

One choice all joint venture devotees face in negotiating each new venture is who to designate as the tax matters partner. Recent changes to the law make this decision much more important and may prove costly to those who are...more

Staffing agency workers and ACA offers of coverage

The final regulations on the Affordable Care Act’s (ACA) “pay or play” rules were released on Feb. 10, 2014. Under the rules, there are potential penalties imposed on large employers that do not offer substantially all...more

Navigating the New Partnership Audit Rules: Sea Change or Same Course?

The recently enacted Bipartisan Budget Act of 2015 amended existing Internal Revenue Code of 1986, as amended (the “Code”) rules governing tax audits of partnerships in the U.S. These new rules primarily impact partnerships...more

IRS Concludes Upper-Tier Disregarded Entity is Continuation of Historical Partnership

The IRS favorably ruled that an internal partnership restructuring was essentially a “nothing” for tax purposes even though the transaction moved the tax-regarded partnership to a different state-law entity. Specifically, in...more

Employee Benefits Developments - January 2016

IRS Guidance Addresses Numerous ACA Issues Related to HRAs. Just before the New Year, the IRS issued Notice 2015-87 (Notice), addressing the application of Affordable Care Act (ACA) market reform rules to different...more

Not Enough Activity to Be a Developer

If you suffer a loss on the disposition of real property, you want to be treated as a developer for income tax purposes - that is, to be treated as engaged in a trade or business. That way, you can get ordinary loss treatment...more

Tax Exclusions for Sale of Stock Issued by Qualified Small Business Corporations Becomes Permanent — At Least Temporarily

Over the past several years, Congress has sought to incentivize investment in small businesses by allowing taxpayers to exclude gains in certain small business stock sales. Gradually, Congress continued to increase these...more

French Finance Act for 2016 and Amending Finance Act for 2015: The Most Important Changes Affecting Businesses

The French Finance Act for 2016 and Amending Finance Act for 2015 were enacted on December 30, 2015 (the “Acts”). Under the new legislation, the neutralization of the 5% add-backs on dividends within tax-consolidated groups...more

The Delaware Competes Act Signed Into Law

This week, Delaware Governor Jack Markell signed into law HB 235, otherwise known as the Delaware Competes Act of 2016. HB 235 was passed by the Delaware State House of Representatives on January 14, 2016 and the Delaware...more

Disclose of Cash Real Estate Purchases

The purchase of real estate without bank financing presents an opportunity for those with unclean funds to launder those funds and make them appear legitimate, at least in the opinion of the Financial Crimes Enforcement...more

Landlords and tenants: To Airbnb or not Airbnb, that is the question

If you own or occupy residential real property, a question may come to mind. As Shakespeare might have put it, “To BNB or not BNB, that is the question.”...more

California Supreme Court Denies BOE Petition for Review in Lucent Technologies

Last week, the California Supreme Court denied the State Board of Equalization’s (BOE’s) petition for review in Lucent Technologies, Inc. v. State Bd. of Equalization, No. S230657 (petition for review denied Jan. 20, 2016)....more

New Partnership Audit Rules Require Careful Review of Partnership and LLC Agreements

If you are a partner of a partnership or a member of a limited liability company (LLC) taxed as a partnership, or are entering into a new partnership or LLC, you may have some important decisions to make in light of impending...more

RF Supreme Court Judges deny review of Oriflame Cosmetics by the Judicial Panel for Economic Disputes

RF Supreme Court Ruling No. 305-K?15-11546 of 14.01.2016 denied the transfer of the cassation appeal by OOO Oriflame Cosmetics against adverse judgments to the Judicial Panel for Economic Disputes for consideration in a court...more

[Webinar] Golden Parachute Tax Terror: A tax law webinar presented by Kimberly Swintosky - Feb. 11th, 1:00pm, EST

Smith Anderson's tax group is now offering complimentary presentations. This webinar will provide an introduction to the tax rules related to certain payments to insiders triggered by a change in control of a corporation...more

The Arbitration Court declares it legal to deduct license fees for use of trademarks

The Arbitration Court declares it legal to deduct license fees for use of trademarks - The Moscow Arbitration Court rendered the Decision of December 31, 2015 on case No. ?40-153860/15. The case was essentially about the...more

Supreme Court of Pennsylvania Holds Lease Exception of Local Tax Enabling Act Does Not Prevent Business Privilege Tax from...

On December 21, 2015, the Supreme Court of Pennsylvania held that the exception in 53 P.S. §6924.301.1(f)(1) of the Local Tax Enabling Act (LTEA), which prohibits the taxation of leases and lease transactions, does not...more

Recent development on taxation of securities lending transactions

On 13 January 2016 the German Federal Finance Court (Bundesfinanzhof –“BFH”) published its ruling on securities lending transactions (“Ruling”). The Ruling was long-awaited and rumor had it that it might bring about a...more

Taxability of Shipping and Handling Charges in Illinois – Common Sense Prevails in Department's Second Notice of Proposed...

On January 14, 2016, the Illinois Department of Revenue (the “Department”) sent its Second Notice of Proposed Rulemaking to the Joint Committee on Administrative Rules (“JCAR”) regarding its proposed amendments to its...more

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