Finance & Banking Tax

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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

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 Proving Big...more

Highlights of Final Regulations for Reporting of Specified Foreign Financial Assets

The Treasury Department has issued final regulations relating to reporting of specified foreign financial assets on Form 8938. The highlights include...more

IRA “Charitable Rollover” Retroactively Extended Through 2014

Background - As a part of the so-called “Cromnibus” bill, Congress has extended dozens of expired “temporary” tax breaks for 2014. Included in that group is a rule that allows for tax-free treatment of certain...more

IRA Charitable Rollover Extended

For some, the end of the calendar year means more than just the deadline for charitable contributions for the tax year. December 31 is also the deadline to take certain mandatory distributions from individual retirement...more

Compensation Issues – Revisited

We have completed another retirement plan audit season and have noticed a number of common errors occurring with compensation. I previously discussed these issues in my blog series “Compensation: The Missing Link – Part 1”...more

IRS Simplifies Tax Reporting for Individuals With Canadian Retirement Plans

Under Article XVIII(7) of the United States-Canada Tax Treaty, a U.S. citizen or resident may elect to defer U.S. income taxation on income accruing under a Canadian registered retirement savings plan (RRSP) or registered...more

Senate passes Tax Extender Package at 11th hour

The Senate passed the “Tax Increase Prevention Act of 2014? (H.R. 5771) on Tuesday night just before Congress adjourned for 2014. As Molly Bryson described in her December 5, 2014 post following the House’s passage of the...more

FCA Dismisses Lord Black’s Tax Appeal

Earlier this year, in Black v. HMQ (2014 TCC 12), Lord Conrad Black unsuccessfully argued in the Tax Court of Canada that, due to his U.K. residency status, he should not be subject to Canadian tax on certain income and...more

Were These The Extenders That We Were Waiting For?

The Senate on December 16 passed a tax bill that retroactively extends a package of fifty-five tax provisions through the end of 2014. In other words, by the time President Obama signs the new law, it will remain in effect...more

One 60-Day IRA Rollover Per Year Is The Final Answer

Although the Internal Revenue Code trumps IRS Publications, practitioners tend to use the Publications as the initial resource when handling day-to-day tax issues. However, the Publications were not part of petitioner’s...more

VAT Charged On Invoices Relating To Defined Benefit Occupational Pension Schemes – All Change For HMRC’s Approach

HMRC has released new guidance dealing with the ability of sponsoring employers to recover input VAT in respect of supplier costs for running defined benefit occupational pension schemes. These costs will typically involve a...more

Benefits of P3 Model – Rebuttal of Ontario Auditor General’s Report

On December 9, 2014, Ontario’s Auditor General released her 2014 Annual Report, sharply criticizing Ontario’s Alternative Financing and Procurement (AFP or P3) program and suggesting a return to using the traditional method...more

Deferral Elections for 2015 Compensation

As reported in Part 3 of our 2014 End of Year Plan Sponsor “To Do” List, employers that sponsor deferred compensation programs should take action to ensure that deferral elections that apply to compensation that will be...more

Settlement in RDS/Alatax Class Action Lawsuit Tentatively Approved

In September 2010, a small group of Alabama taxpayers brought a second class action lawsuit against Revenue Discovery Systems/Alatax (“RDS”) alleging that RDS and its auditors committed multiple violations of the Alabama...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

NYS Department of Taxation and Finance Issues Tax Guidance on Virtual Currency Transactions

On December 5, the New York State Department of Taxation and Finance (DTF) issued the memorandum “Tax Department Policy on Transactions Using Convertible Virtual Currency.” The memorandum clarified that under New York law,...more

Enactment Imminent for Section 529A Tax-Exempt Savings Programs for Disabled Beneficiaries

On December 16, 2014 the U.S. Senate approved the Achieving a Better Life Experience (“ABLE”) legislation previously approved by the House, authorizing state-sponsored tax-exempt savings programs for disability-related...more

Hybrid Mismatches – UK Proposals for Implementing the BEPS Recommendations

The United Kingdom made its first substantive commitment arising out of the base erosion and profit shifting (BEPS) initiative on 3 December 2014, with the release of a consultation paper on implementing the agreed G20-...more

Spotlight On Federal Tax Developments In 2014

This article highlights a number of interesting federal tax developments that were brought to the table during the 2014 calendar year. Developments discussed in this article include the 18-month transitional period for the...more

The Economic Development Toolbox: “The Clean-Up Hitters” – Enterprise Zone and Community Reinvestment Area Property Tax Exemptions

Capital investment projects often involve tight margins, and every single dollar counts to ensure that the project is a success. For that reason, property tax exemptions are key components of any economic development...more

Stuff That Won’t Help A Retirement Plan Sponsor Limit Their Liability

As eat belt in a car is useless if the driver or passenger isn’t wearing it. A smoke detector is useless if the batteries are dead. Vitamin C won’t prevent a cold and putting paper on your forehead won’t cure hiccups. For a...more

2014 Year-End Tax Update

I. A LOOK BACK AT 2014 TAX MATTERS: A. Some Random Observations - ..1. This year’s update is brought to you by the letter “I,” as in “inversions.” ..2. Tired of waiting for Congress to address what they...more

Fund Sponsor Entities With San Francisco Activities May See Significant Tax Increases Under Gross Receipts Tax

San Francisco’s gross receipts tax (GRT) began phasing in this year and will be fully implemented in 2018. While the tax rates are lower than those under the previous payroll tax system, the GRT may lead to higher taxes for...more

FATCA Update: Treasury Extends Time for Jurisdictions with Agreed-in-Substance IGAs to be Treated as if They Had an IGA in Effect

On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements....more

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