General Business Tax

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Tightening the Tax Screws on International IP Structures

For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more

A Buyer’s Guide to Acquiring Target’s Assets With A Stepped-Up Basis

The last few posts have focused upon the “tax-free” contribution of property to a partnership. Today, we’re “doing a 180,” as they say (whoever “they” are), and considering how the acquisition of assets may be structured so...more

NJ Guidance on State Tax Addback: Refund Opportunity for Taxpayers Adding Back Capital Stock or Bank Taxes

For purposes of computing New Jersey corporation business tax, the statute requires a taxpayer to add back any taxes paid to other states on or measured by profits or income, or business presence or activity. Yesterday, the...more

Your Daily Dose of Financial News

The struggle to attract and retain businesses and the jobs they provide has increasingly led to states and cities squaring off against others, with competing tax incentive packages the very real currency of the battle....more

Important New Business Tax Proposals for U.S. Tax System

During the past few months, there has been considerable speculation over potential changes to the U.S. tax system that could have an impact on international businesses. At this stage, the discussions are preliminary and the...more

Tax and non-executive directors

In the 2016 Budget Review, the Minister of Finance stated that in terms of the Income Tax Act 58 of 1962 (the ITA) and the Value-Added Tax Act 89 of 1991 (the VAT Act), a non-executive director’s (NED) fees may be subject to...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

German Corporate Newsletter - March 2017

For companies interested in investing in, purchasing or selling German companies, here are several recent developments related to Data Privacy and Cybersecurity, M&A, Employment and Tax law that are helpful to keep in mind....more

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

The Walking Dead - Using Private Placement Variable Deferred Annuity Contracts to Enhance the Investment Return in Life Settlement...

Overview - I have always been a film fan. Growing up in the Panama Canal Zone, one of my Mother’s jobs for the Panama Canal Company was serving as the manager of the Balboa Theater. We used to watch initial screenings of...more

Effecting Exchanges of Property Through a Partnership

In the last two posts, we saw how a Taxpayer who transfers Property A to a partnership (“Partnership”) in exchange for an equity interest therein will not be required to recognize the gain realized on the transfer. This gain...more

The U.S. Tax Reform and the Energy Sector

President Donald Trump and Republican Congressional leaders have promised a major reform to the U.S. tax code in 2017. This reform, if anything close to these promises, will have significant implications for the energy...more

Florida Department Of Revenue Issues Advisement Determining That A Reinsurer And Its Cedents Did Not Have Nexus In Florida For Tax...

On January 13, 2017, the Florida Department of Revenue issued a Technical Assistance Advisement regarding whether a reinsurer had nexus with the state of Florida that would require it to file a corporate income tax return and...more

“W-2 Phishing Attacks Targeting Businesses to Cash in on Busy Tax Season: 10 Tips to Protect Your Business”

Cyber criminals are taking advantage of tax season to lure valuable W-2 information from vulnerable businesses. An example of a common phishing scheme starts with a scammer posing as a legitimate employee of a company,...more

Minnesota Weekly Legislative Update: Legislation Continues to Move as First Committee Deadline Nears

Today marks the first committee deadline in the legislative session. By midnight tonight, bills must be approved by policy committees in the House or the Senate. Next Friday is the second committee deadline, by which all...more

House Blueprint’s Destination-Based Cash Flow Tax: A Primer

The election of Donald Trump in November has substantially increased the likelihood of major tax reform in the near future. While it is uncertain what shape such reform will take, there has been renewed interest in the...more

Rating – the road to revaluation: Material change of circumstances

You instruct a specialist rating surveyor, who carries out detailed calculations to ascertain your rateable value (RV) and engages in lengthy negotiations with the Valuation Officer (VO) – then something changes at your...more

Business rates revaluation 2017: an explanation

On 1 April 2017 the business rates payable in respect of properties in England and Wales will be changing. Business rates are the tax that businesses pay on the retail, office and industrial premises that they occupy. ...more

Funds Bulletin - February 2017

Funds Bulletin (a monthly round-up of topical legal, regulatory and tax issues affecting the fund industry). Features our summary of the FSCP's position paper on the impact of Brexit on financial services consumers, as well...more

Charitable Organizations And Political Activities

Recent media attention has been given to proposals to repeal the prohibition on political activities by charitable organizations exempt from taxation under IRC 501(c)(3) – commonly referred to as the “Johnson Amendment”. ...more

Protecting Tax Deferral for A Contribution to A Partnership

When a taxpayer (“Taxpayer”) sells a property (“Property”) with a fair market value (“FMV”) in excess of Taxpayer’s basis in Property in exchange for cash in an arm’s-length transaction, the amount of gain that he realizes on...more

IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

Rating – the road to revaluation: Valuation

Valuation - The front pages of the national press have been headlining a key message: the revaluation and proposed reforms are taking businesses on a path they are resistant to going down. In view of a plethora of hard...more

TIC Form SHC Deadline Approaching to Report U.S. Ownership of Foreign Securities

The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC) data reporting system. Form SHC is the mandatory five-year...more

Key Takeaways: Prospects for US Business Tax Reform — What You Need to Know

On February 16, 2017, Skadden hosted a webinar titled “Prospects for U.S. Business Tax Reform: What You Need to Know.” The Skadden panelists were M&A partner Stephen Arcano; global tax co-head Eric Sensenbrenner; and tax...more

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