News & Analysis as of

General Business Tax

Read need-to-know updates, commentary, and analysis on General Business issues written by leading professionals.

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

Outline for Discussion of New Issue Price Rules

New tax rules relating to establishing the issue price of publicly offered tax-exempt bonds become effective soon. This outline describes the new issue price rules, provides a high-level strategic analysis to help guide a...more

FRANCHISOR 101: State Taxes on Franchise Fees

by Lewitt Hackman on

Franchisors collect weekly or monthly "franchise fees." In many cases, fees are for particular services, such as marketing assistance or IT support. In franchising, the parties may be in any number of different states: for...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

Update on Transaction Costs - 'Origin of the Claim' Analysis Will Decide Tax Allocations - Tax Update Volume 2017, Issue 3

by Pepper Hamilton LLP on

While the Internal Revenue Service (IRS) has continued to issue guidance addressing the ability to deduct transaction costs, the doctrine of "Origin of the Claim" (OOC) developed over 50-plus years of case law is still the...more

Law à la Mode: Special Edition - INTA 2017

by DLA Piper on

The Belgian editorial team is delighted to bring you this special edition of Law a` la Mode, marking the 139th INTA Annual Meeting in Barcelona. Just some of the focuses for this special edition include the dangers of...more

California FTB Provides Guidance on Certain Section 382 Calculations - Tax Update Volume 2017, Issue 3

by Pepper Hamilton LLP on

California requires taxpayers that have income within and outside the state to "apportion" their overall income between the two categories based upon certain factors and rules for determining their California tax liability....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

Insurance Proceeds Payable To Tenant Diverted To Pay For Property Owner's Back Taxes

The Third Circuit Court of Appeals sitting in Pennsylvania recently issued a precedential decision that interpreted the definition of a “named insured” under a tax delinquency statute to encompass tenants of a property even...more

Italy passes new rules for carried interest

by Hogan Lovells on

The Italian Government has at last put an end to the controversy around the characterisation of 'carried interest' for tax treatment purposes. By Law Decree no. 50 of 24 April 2017, which is to be brought into law by 23 June...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

Tax Round Up - May 2017

by Proskauer Rose LLP on

Budget and Finance Bill - General Election – Finance Bill (No.2) 2017 Curtailed - The Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May...more

Section 83(b) Elections Add Value To Equity Grants

by Cole Schotz on

Contractors, advisers, and employees (collectively, “Service Providers”) who receive property that is non-transferrable or subject to a substantial risk of forfeiture must generally defer their income recognition until those...more

Why Care About Business Valuation? Part I

by Farrell Fritz, P.C. on

One word: “taxes.” There are so many transactions in which the tax consequences visited upon a closely-held business and its owners, and, therefore the true economic cost of the transaction, will depend upon the valuation of...more

Federal Tax Reform Legislation in 2017: Comments by Attorney Morris N. Robinson

Attorney Morris N. Robinson, the Managing Director of M. Robinson Tax Law in Boston, recently published an op-ed titled: Viewpoint: A 15 percent tax rate on business would maximize economic growth....more

Tenth Circuit Holds Marijuana Dispensary Not Entitled To Injunctions Against IRS

by Fox Rothschild LLP on

In The Green Solution Retail v. U.S., Case No. 16-1281, 10th Cir, May 2, 2017, the Tenth Circuit agreed with the District Court that a marijuana dispensary was not entitled to injunctions intended to stop an IRS examination...more

Commercial Division Rejects Third-Party Claim as Derivative in Trusts’ Suit Concerning Upper West Side Beaux-Arts Building

Asserting a claim on behalf of a trust in the Commercial Division can be risky, as the party asserting the claim must establish that the claimed injury is independent of any injury to the trust, and that they are therefore...more

Digital Single Market: the European Commission Takes Stock and Defines Future Priorities

by Latham & Watkins LLP on

The Commission’s mid-term review assesses the progress of DSM initiatives and sets new goals for on data economy, cybersecurity and online platforms. On 10 May 2017, the European Commission published its mid-term review...more

Energy Transfer, Williams, and the Circular Ownership of Stock

It is unheard of for a deal to die at the closing table because lawyers cannot deliver a required opinion regarding a transaction that they structured and negotiated. Yet, this is exactly what happened last year when two...more

Il nuovo regime fiscale dei piani di co investimento di amministratori e dipendenti

L'articolo 60 del d.l. n. 50 del 24 aprile 2017, pubblicato in G.U. 24 aprile 2017 (di seguito "Decreto"), disciplina il regime fiscale applicabile ai redditi derivanti dalla partecipazione ad OICR, società o enti percepiti...more

Is a lease always just a lease?

by Shutts & Bowen LLP on

For one Miami-Dade County shopping center owner, the answer is now yes, but only after a ruling from Florida’s Third District Court of Appeal in Garcia v. Dadeland Station Associates, Ltd. In 2015 that owner found itself...more

Waiver of contractual right

by Hogan Lovells on

In a binding private ruling published on 2 May 2017, SARS was requested to confirm the income tax, donations tax, capital gains tax and value-added tax consequences of the proposed waiver of a right to receive an annual...more

MoFo New York Tax Insights - Volume 8, Issue 5

by Morrison & Foerster LLP on

Final 2017-18 New York State Budget Bill Enacted - The New York State Budget Bill was enacted by the New York State Legislature and signed into law by Governor Andrew M. Cuomo. S. 2009-C, A. 3009-C. Among the Governor’s...more

Nasdaq Report: Reigniting America’s Economic Engine

The Nasdaq recently published a report, titled “The Promise of Market Reform,” which sets out proposed structural changes that are intended to relieve some of the burdens associated with being a public company. The report...more

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