General Business Tax

Read need-to-know updates, commentary, and analysis on General Business issues written by leading professionals.
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Mexico 2017 Repatriation Tax Amnesty

A new amnesty program to incentivize the repatriation of funds kept abroad by Mexican taxpayers was launched. The program will be open until mid-2017 and participants would be obliged to comply with specific requirements,...more

Client Alert: New Revenue Procedure 2017-13 Provides Clarification of Safe Harbors for Management Contracts of Tax-Exempt Financed...

The Internal Revenue Service has issued Revenue Procedure 2017-13 that clarifies certain provisions of Revenue Procedure 2016-44. For a full explanation of the provisions of Rev. Proc. 2016-44, see our client alert of August...more

[Webinar] Fiduciary Income Tax Refresher and Update - February 7th, 12:00pm CT

In the webinar the presenters will discuss tax-savings tools that can be used between now and March 6 when preparing 2016 returns. The presenters will provide a top-ten list of planning tips to help attendees save income tax...more

2017 California Estate and Tax Planning Newsletter

Blank Rome’s annual estate and tax planning newsletter addresses estate planning concepts and techniques that should be considered in 2017 by our clients and friends. Transfer Taxes. The major changes made in 2010 in the...more

Border-Adjustable Taxes under the WTO Agreements

This client alert summarizes the World Trade Organization (WTO) disciplines on border adjustable internal taxes and provides a general framework for assessing any future United States corporate tax plan that incorporates a...more

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more

Base erosion and profit shifting - new regulations

International tax issues have never been more prevalent than in today's integrated economic environment and international markets. As the world becomes increasingly globalised and cross-border activities become the norm, the...more

Management Contracts Safe Harbors Revisited – IRS Releases Updated Guidance (Again)

Demonstrating the “user-friendly” side of the IRS, on January 17, 2017, the IRS released Revenue Procedure 2017-13 (“Rev. Proc. 2017-13”) (available here) to address many (but not all) of the comments received on the rather...more

Annual Reporting Requirements for Incentive Stock Options and Employee Stock Purchase Plans

Annual Information Statements and IRS Returns - Requirement to Report - For (1) any exercise of an incentive stock option ("ISO") during 2016 or (2) transfer during 2016 of a share previously purchased pursuant to a...more

Indiana Tax Court deep freezes sales tax exemptions for Warehouse Operator’s purchases of equipment and electricity

In Merchandise Warehouse Co., Inc. v. Indiana Department of State Revenue (Jan. 11, 2017), the Indiana Tax Court rejected a Taxpayer’s request for a sales tax exemption for certain freezer equipment and the electricity used...more

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Proposed Loss of Interest Deduction Would Boost Cost of PE Deals

Where asset acquisitions or deemed asset acquisitions are not available, the loss of the interest deduction would likely result in an increased focus on pure equity-funded transactions. Originally published on the Middle...more

Loans Between Related Entities

What Was Intended? Over the last thirty years, I have reviewed the income tax returns of many closely held corporations and partnerships. Quite often, on Schedule L (the balance sheet), I will see an entry for “other...more

Split Dollar Shing-a-Ling! Employing the Concepts of Inter-Generational Split Dollar in Compensatory Split Dollar Arrangements

Overview - In the last ten years, life insurance producers and their counsel have quietly transferred great fortunes with minimal gift and estate taxation using intergenerational split dollar life insurance programs....more

Weekly Update Newsletter - January 2017 #2

GOVERNMENT CONTRACTS - Federal Acquisition Regulation; Federal Acquisition Circular 2006-95 - This Federal Acquisition Circular provides a summary presentation of final rules issued by the Department of Defense...more

Can a PA Employer be Liable to its Employees for a Data Breach?

It’s a nightmare scenario for any employer: you’ve been hacked. Thousands of your employees’ names, birthdates, Social Security numbers, and bank account information have been stolen. This information is used to file...more

Key Takeaways From Delaware’s Unclaimed Property Overhaul

A bill has been introduced in the Delaware Senate that would overhaul Delaware’s unclaimed property law. The bill is on a fast track and could be enacted by the end of January. If enacted, companies currently under audit will...more

Boozelaw: TTB Adopts Changes Designed to Benefit Startup Brewers, Winemakers and Distillers

For certain brewers, wine makers and distillers, the gift-giving season did not necessarily end in December. The Alcohol and Tobacco Tax and Trade Bureau (TTB) recently announced it has adopted changes that may impact the tax...more

The PFIC Regulations Get a Facelift

On December 28, 2016, the Treasury issued final regulations (T.D. 9806) that primarily address passive foreign investment company (PFIC) ownership and reporting rules and largely adopt 2013 proposed (REG-140974-11) and...more

New IRS Reporting Rule Could Bite Unwary Foreign Investors

There are two main sources of reporting requirements for foreign investors in the United States — the Internal Revenue Service and the Bureau of Economic Analysis. The IRS recently upped its game by requiring reports from...more

ITC Solicits Public Comments On MTB Petitions - 45-Day Comment Period Open Until February 24, 2017

The U.S. International Trade Commission (“ITC”) is now accepting public comments on Miscellaneous Tariff Bill (“MTB”) petitions for duty suspensions and reductions that timely were filed with the agency by December 12, 2016,...more

MoFo New York Tax Insights - Volume 8, Issue 1

The Top 10 New York Tax Highlights of 2016 - It’s the New Year, and before we begin afresh, we look back at this past year with our list of the Top 10 New York tax highlights of 2016. 1. The New York State Tax...more

Waking Up from a Long Winter’s Nap … the Border Adjustment Tax is the Sleeper Issue in the House Republican Tax Reform Blueprint

Thanks to the Republican sweep of the White House and the Congress, all the talk in recent years about tax reform is on the verge of turning into action. What many dismissed as idle chatter before Election Day suddenly...more

HMRC Publishes Guidance on the Tax Treatment of Clawback of Remuneration in the UK

Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...more

TTB Changes Under the Fall Edition of the Unified Agenda

On December 23rd, 2016 the federal government published its Fall edition of the “Unified Agenda” – a bi-annual compilation of all ongoing federal rulemaking projects. Attached is a copy of the TTB detail from this latest...more

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