General Business Tax

Read need-to-know updates, commentary, and analysis on General Business issues written by leading professionals.
News & Analysis as of

Swimming in the Deep End – The Surprising Utility of Pooled Income Funds for High Net Worth Tax Planning

Overview - The old cliché about Charity is that “Charity begins at home.” The federal government has always recognized the social benefit of providing tax incentives for individual and corporate taxpayers in order to...more

Spotlight on Tennessee: Letter Ruling Addresses Treatment of a Section 338(h)(10) Election

Tennessee does not expressly conform to most provisions in Subchapter C of the Internal Revenue Code. Instead, Tennessee's federal corporate income tax conformity is determined based on the "starting point" that Tennessee...more

CBSA Announces Mid-2014 Audit Targets

As is its practice, the Canada Border Services Agency recently announced its semi-annual trade verification targets for the balance of 2014. Many targets continue from the past, while new ones have been added....more

Rules Will Allow Issuance of Longevity Insurance in Retirement Plans

On July 1, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final rules excluding qualifying longevity annuity contracts (QLACs) from the required minimum distribution rules (RMD...more

Introduction of the Exploration Development Incentive

In the 2014 Budget, the Federal Government announced that it would introduce Exploration Development Incentive (EDI) tax credits to encourage and stimulate growth in the junior mining industry. This is a simpler approach to...more

Department of Commerce Announces Preliminary Decision to Impose Tariff on Solar Panels Imported From China

Some U.S. solar equipment manufacturers have lauded the Department of Commerce’s recent decision to impose high tariffs on solar panels imported from China as the end of China’s unfair market advantage; however, from the...more

German Federal Government Plans Tax Exemption of INVEST – Subsidy for Venture Capital

The German Federal Government has given an important insight to its plans and future measures regarding taxation of the start-up- and VC-ecosystem in Germany by officially answer to a parliamentary request by several members...more

Senate Finance Committee Considering Measure to Largely Repeal IRC Section 530 Safe Harbor for Most Businesses Using Independent...

Sen. Sherrod Brown (D.Ohio) reintroduced the “Fair Playing Field Act,” S.1706, in November 2013. The bill, which first appeared in 2010 under then-Senator John Kerry’s sponsorship, purports to close an ostensible loophole in...more

Le novità introdotte dal Decreto Crescita: Minibond, concessione di finanziamenti e cartolarizzazione dei crediti

In data 24 giugno 2014, è stato pubblicato in Gazzetta Ufficiale n. 144, il decreto legge 24 giugno 2014 n. 91 (il "Decreto Crescita") che introduce: (i) misure a favore delle emissioni di obbligazioni...more

IRS Pursues 409A Audits, Issues Ruling on Certain Options/SARs under 457A

IRS audits signal focus on Section 409A compliance; Revenue Ruling makes certain nonqualified options and stock appreciation rights more attractive for offshore entities. The IRS has begun its limited audit initiative...more

Supplemental Interagency Guidance on Tax Allocation Agreements

The federal bank regulators recently issued additional guidance on intercompany income tax allocation agreements between holding companies and their depository institution subsidiaries. Intended to clarify the ownership of...more

M&A Update | Inversions: The View from Ireland

On June 25, 2014, Ireland’s Taoiseach (Prime Minister) Enda Kenny and Minister for Finance Michael Noonan, among others, met with Cadwalader Chairman-elect and Corporate Group Co-Chair James C. Woolery in Dublin regarding...more

Revised CRA Policy Heralds Focus on Contemporaneous Transfer Pricing Documentation

CRA released an updated transfer pricing memorandum, TPM-05R, Requests for Contemporaneous Documentation, in March, which describes the procedural aspects of transfer pricing documentation requirements in substantially more...more

United States Prevails in WTO Dispute Challenging China's Duties on U.S. Automobiles

Last month, a World Trade Organization (WTO) Panel issued a report favorable to the United States, ruling against Chinese duties on American auto exports. China had imposed tariffs on U.S. cars and SUVs with engine capacities...more

Tax authorities updated their interpretation of certain transfer pricing issues

On 1 July 2014, the Ministry of Revenues and Levies of Ukraine has issued Order #368 "On amendment of Generalized tax consultation on transfer pricing related issues, adopted by the order #699" (hereinafter - the Order) which...more

Final Noncompensatory Partnership Options Regulations Could Affect the Tax Treatment of Penny Warrants and Other Arrangements

Investments in partnerships (and other pass-through entities such as limited liability companies treated as a partnership) often involve the acquisition of warrants, options or other rights to acquire securities. This is...more

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

The IBC Act – the building of a nation

Although nobody knew it at the time, the inception of the BVI’s International Business Company Act occurred at some point during the year 1976. Nobody now recalls the exact date, except that it was during the summer.It is...more

Summary of the 2014 Mississippi Taxpayer Fairness Act

This omnibus tax legislation, House Bill No. 799, was signed into law by Governor Phil Bryant on April 11, 2014, after passing the House of Representatives by a unanimous vote 121-0, and by a Senate vote of 40-9. This...more

Japan To Reduce Corporate Income Tax Rate

The corporate income tax rate in Japan is known to be one of the highest worldwide. To encourage foreign companies to do business in Japan and make Japan a more attractive location for investments, Prime Minister Shinzo Abe...more

Orrick's Derivatives in Review - July 2014

Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more

Court of Federal Claims: Merged Corporations are the Same Taxpayer for Interest Netting

In Wells Fargo, the Court of Federal Claims held that a taxpayer may net underpayment balances and overpayment balances among merged entities under Section 6621(d). Section 6621(d) provides that, to the extent the “same...more

RMD Rules for Longevity Annuities Finalized

Longevity annuities are contracts that provide life annuity payments typically commencing at age 80 or 85; in many (but not all) cases, that is the only benefit the contract provides. As such, these contracts may offer...more

San Juan – The New Havana?: Making the Move from Miami to Puerto Rico

I lived in Miami for about ten years during the time that I went to law school at the University Of Miami School of Law, i.e. the Harvard of the South! I also worked in Miami while I went to law school at night and have a...more

Il “Decreto Crescita” e gli interventi sulla disciplina fiscale delle obbligazioni emesse da società non quotate e dei...

In data 24 giugno 2014, è stato pubblicato in G.U. n. 144 il decreto legge n. 91 (c.d. “Decreto Crescita”), in vigore dal 25 giugno 2014, recante inter alia disposizioni urgenti per le imprese. Gli articoli 21 e 22 del...more

2,013 Results
|
View per page
Page: of 81

Follow General Business Updates on: