General Business Tax

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High Net Worth Family Tax Report, Vol. 9, No. 3

In This Issue: - Tax planning strategies to consider before the end of the year - The IRS announces inflation-adjusted amounts for 2015 - Case update: Taxpayer’s deduction for interest capitalized in loan...more

Currency Conversion Concerns: New York Issues Guidance on Virtual Currencies

On December 5, 2014, the New York Department of Taxation and Finance (Department) released TSB-M-14(5)C, (7)I, (17)S. This (relatively short) bulletin sets forth the treatment of convertible virtual currency for sales,...more

Sol-Wind’s IPO Compared to YieldCos & Structures of Other MLPs

Yesterday, Sol-Wind filed its S-1 with the Securities & Exchange Commission for its listing on the NYSE. Its ticker symbol will be SLWD. Here is a link to my structure diagrams for Sol-Wind and comparisons of it to a...more

Louisiana Court Holds Video-on-Demand and Pay-Per-View Are Not Tangible Personal Property

Today the Louisiana Fifth Circuit Court of Appeal held that a cable television provider’s video-on-demand (VOD) and pay-per-view (PPV) programming services are not tangible personal property and therefore not subject to sales...more

Summary of the Tax Extenders in the Tax Increase Prevention Act

On Friday, December 19th, President Obama signed the Tax Increase Prevention Act (“TIPA”), H.R. 5771, into law. TIPA is commonly referred to as the “tax extenders” bill as it extends certain expiring provisions of the...more

Congress Extends QZABs, New Markets Tax Credits; Continuing Effect of Sequestration

Qualified Zone Academy Bonds - The Act authorizes the Secretary of the Treasury to allocate an additional $400 million in QZABs for 2014. Prior to the Act, no additional allocations of QZABs were to be available to the...more

U.S. Department of Commerce Announces Final Tariffs on Chinese and Taiwanese Solar Products

On December 17, 2014, the U.S. Department of Commerce (DOC) announced its final determinations in the antidumping duty (AD) and countervailing duty (CVD) investigations of crystalline silicon photovoltaic products (“solar...more

Want to get paid like Darryl Strawberry?

The IRS is auctioning off a deferred compensation arrangement Darryl Strawberry had with the Mets. Minimum bid is $550,000 for a payment stream that is estimated to be well over $1 million. Get your bid in by January 20th...more

Tax Law Extension Good News for Non-corporate Investors

Congress once again temporarily extends the 100 percent capital gains exclusion on “qualified small business stock.” On December 19, 2014, President Obama signed the Tax Increase Prevention Act of 2014 (the 2014 TIPA)...more

Section 363 Sale Order Enjoining Successor Liability Claims Not Subject to Subsequent Attack by State Agencies

A recent decision in the ongoing bankruptcy proceedings for Chrysler has reinforced the authority of a bankruptcy court to interpret its own sale orders, and where appropriate, to enforce such an order by preventing creditors...more

Congress Approves Tax Extension Bill

TWO WEEKS ONLY! SAVE NOW! Congress has finally approved the extenders bill in what is widely viewed as terrible tax policy, but a welcome holiday gift nonetheless. The Tax Increase Prevention Act of 2014 extended a...more

UK Targets Corporate Profits Of Multinational Enterprises With Sweeping Tax Changes

On December 3, the UK Government announced its intention to introduce a new “diverted profits tax” (DPT) to take effect on April 1, 2015. Draft legislation was published on December 10 and is now subject to a public...more

Pennsylvania Unwraps Final Market-Sourcing Guidance

The Pennsylvania Department of Revenue (the Department) recently finalized its Information Notice on sourcing of services for purposes of determining the appropriate net income and capital franchise tax apportionment factors....more

Tax Extenders Signed into Law; Production Tax Credit Extended for Facilities Beginning Construction in 2014

Earlier today, President Obama signed the Tax Increase Prevention Act of 2014 (H.R. 5771) into law, following its passage through Congress on Tuesday. Among other things, the act will provide a one-year retroactive extension...more

Tax Law Alert: The Tax Increase Prevention Act of 2014 Extends Expired or Expiring Provisions

Congress this week passed the Tax Increase Prevention Act of 2014 (the Act), which is expected to be signed by President Obama at any time. The Act renews or extends a number of expired or expiring provisions. Some of the...more

Corporate & Tax E-Note - December 2014

In this issue: - SEC Crowdfunding Rules Delayed Until October 2015 - Mega M&A Experiencing One of Biggest Booms in History - Some Small Business Owners Say Tax Break Extension Not Enough - 2014...more

Congress Passes One-Year Extension of Business and Individual Tax Provisions

On December 16, 2014, the Senate voted 76-16 to pass H.R. 5771, the Tax Increase Prevention Act of 2014 (“TIPA”), which was passed by the House by a vote of 378-46 on December 3, 2014. TIPA would extend over fifty (50)...more

Deregulate Local Government for Economic Growth: Streamlining Local Option Income Taxes and Other Reforms Can Unleash Indiana’s...

Indiana’s leaders have worked diligently over the past ten years to improve the climate for business. Taxes have been capped, cut, and eliminated. Out of date laws have been repealed or reformed, and new regulations have...more

Southeast State & Local Tax: Important Developments - November/December 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast....more

UK Legal HIghlights 2014 And Beyond

Welcome to our 2014 edition of UK Legal Highlights. This publication is a reminder of some of the most important and significant developments DLA Piper reported in 2014, along with some forthcoming developments to look out...more

GST/HST Closely Related Entities Election – New Filing Requirements

If you are planning on adding a closely related GST group election in the new year (CRA Form GST25), you will now need to file it with the CRA. Further, any pre-2015 elections will also have to be filed before the end of...more

Congress passes tax extenders – through the end of 2014: potential impact on tax reform

In the final act of the 113th Congress, the Senate passed and sent to President Barack Obama for his signature the Tax Increase Prevention Act of 2014, extending through the end of 2014 numerous familiar deduction and credit...more

Taxpayer Overcomes New Jersey Amnesty Penalty

The Supreme Court of New Jersey recently affirmed a decision that amnesty and late-filing penalties did not apply to the taxpayers in United Parcel Serv. Gen. Servs. Co. v. Dir., Div. of Taxation, No. 072421 (N.J. Dec. 4,...more

The UK’s New Diverted Profits Tax

The UK Treasury has published the draft legislation for the new Diverted Profits Tax (DPT), which it plans to introduce from 1 April 2015. This has been unofficially described as the “Google Tax”, and represents part of the...more

Directors Need to Meet High Standard to Avoid Liability

The Tax Court of Canada again confirmed that directors of corporations will have a high burden to meet to establish a due diligence defence and avoid liability for unremitted source deductions....more

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