General Business Tax

Read need-to-know updates, commentary, and analysis on General Business issues written by leading professionals.
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Proposed Sec. 367 Regs Say Goodbye to Goodwill Exception

Citing aggressive taxpayer positions, recently proposed regulations do away with the foreign goodwill exception to gain or income recognition for outbound transfers under Section 367. The rules also restrict the type of...more

Treasury and IRS Issue Additional Inversion Notice

The Treasury Department and the IRS released Notice 2015-79 (the “2015 Notice”) on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by Treasury and the IRS on...more

Taxpayers Stand to Lose Under Chicago’s Lease Tax VDA Offer

Yesterday, the City of Chicago (City) Department of Finance (Department) published an Information Bulletin that provides additional guidance on the Personal Property Lease Transaction Tax (Lease Tax) and extends a new...more

Your daily dose of financial news The Brief – 11.20.15

The US Treasury Department and IRS are joining forces to address corporate tax inversions with the introduction of new measures aimed at “curtailing companies’ ability to avoid United States tax rates if they move to...more

Supreme Court of Canada to Hear Tax Rectification Case

On November 19, 2015, the Supreme Court of Canada granted leave to appeal in Canada (A.G.) v. Groupe Jean Coutu (PJC) inc., 2015 QCCA 838, which addresses the question of when rectification will be granted in the tax context....more

M&A Update: Treasury Announces Second Anti-Inversion Notice

On November 19, 2015, Treasury issued Notice 2015-79 (the “Notice”), which announces Treasury’s intent to issue regulations reducing the tax benefits available to inverted groups and making it more difficult for some U.S....more

Vanguard Attorney's Whistleblower Suit Dismissed for a Violation of the New York State Ethics Rule Prohibiting Disclosure of...

On November 13, 2015, the Supreme Court of New York dismissed a former Vanguard Group tax attorney's New York False Claims Act whistleblower complaint against his former employer. The court held that the attorney violated New...more

Global Tax News - November 2015

HANDS OFF DIGITAL CURRENCIES! CANADA’S SENATE CALLS FOR A LIGHT REGULATORY APPROACH Formerly considered a gimmick for geeks and gamers, digital currencies, such as Bitcoin, have grown into a worldwide phenomenon...more

The Gap, the Trap and the Binding Spring - The Bri-Chem trilogy, the rule of law and self-corrections of revenue-neutral tariff...

In three decisions released concurrently by the Canadian International Trade Tribunal (CITT) on September 18, 2015 (collectively referred to as the Bri-Chem trilogy), the CITT instructed the Canada Border Services Agency...more

IRS Announces 2016 Retirement Plan Dollar Limits

The IRS recently announced cost of living adjustments for 2016. In general, the dollar limitations for retirement plans remained the same. The key dollar amounts are noted below, all of which remain unchanged from 2015....more

Michigan Court of Appeals Holds That Cloud Computing Applications Are Not Taxable as Software

On October 27, 2015, the Michigan Court of Appeals issued a much-anticipated decision in Auto-Owners Insurance Company v. Michigan Department of Treasury that has relevance to most Michigan companies concerning whether sales...more

Be Cautious of Late In the Year Mutual Fund Purchases

This is the time of year to be cautious about buying a mutual fund. Many funds pay dividends near the end of the calendar year in December. If you buy one now, and it pays a dividend, you will be paying taxes for 2015 on the...more

European Competition Law Newsletter – November 2015

A company that helps with or facilitates a cartel is at just as much risk of sanctions and penalties as are the actual cartelists. This was confirmed by the EU’s highest court (the European Court of Justice (ECJ)) on 22...more

IRS: Bad News for REIT Spin-off Conversions

In late September, the IRS sent up as large of a red flag as possible concerning Real Estate Investment Trust (“REIT”) spinoffs in IRS Notice 2015-59 and Rev. Proc. 2015-43. While these issuances did not change existing law,...more

Important Revisions to Partnership Tax Audit and Payment Rules

The recently enacted 2015 Budget Act includes a dramatic change in the rules for tax audits of, and the payment of tax deficiencies by, partnerships (including limited liability companies that are taxable as partnerships)....more

BEPS and real estate investment funds: What are sponsors to do?

The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the "Reports") after a two-year consultation period during which 62 countries and many other stakeholders (such as...more

OECD/G20 Base Erosion and Profit Shifting Project — Final Reports Released

On October 5, 2015, the Organisation for Economic Co-operation and Development (“OECD”) published final reports outlining the “actions” to be undertaken by OECD members as part of the base erosion and profit shifting (“BEPS”)...more

New Audit Rules for Partnerships

Last week, President Obama signed into law the Bipartisan Budget Act of 2015.  Buried in this budget bill is an entirely new procedure for how partnerships are audited.  Specifically, it would repeal the  much maligned TEFRA...more

Before Selecting Business Form, What Is Important To Consider? P.2

In our last post, we began discussing the importance of careful planning when selecting the legal form one’s business will take. As we noted, this decision can impact a number of aspects of the business and its owners. The...more

Goodbye TEFRA, Hello New Partnership Audit Rules

Last week, President Obama signed into law the Bipartisan Budget Act of 2015. As I mentioned in a prior post, the budget bill contained a proposal to revamp how partnerships are audited. Specifically, TEFRA (the 1982 Tax...more

Where We Stand on Issue Price for Tax-Exempt Bonds

The U.S. Treasury Department and the Internal Revenue Service (IRS) held a public hearing on the definition of issue price for tax-exempt bonds on October 28, 2015. The hearing is another step in the process of changing what...more

Hospitality, Food and Beverage Industry Newsletter

We are pleased to share the first edition of our Hospitality, Food and Beverage Industry Newsletter with you. This Newsletter addresses important recent legal developments affecting the hospitality and restaurant industry and...more

Succession Planning: “If I get hit by a bus tomorrow…”

Let’s face reality. We are all going to pass on someday, so we might as well be prepared and lessen the burden for those following behind us. One of the first steps in effective succession planning is to gather in one place...more

Last Week's Budget Bill Drastically Changed the Audit Rules for Partnerships

Last week, President Obama signed into law the Bipartisan Budget Act of 2015. While there has been news coverage about the budget agreement, little attention has been paid to the fact that it dramatically changed the manner...more

The Acquisition and Leveraged Finance Review

During the decade preceding the financial and economic crisis, Austria has developed into a buoyant market for both domestic and international M&A activity, with some of the peak years seeing over 400 deals. Compared to...more

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