General Business Tax

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RF Supreme Court consolidates court practice on the application of transfer pricing and thin capitalization rules

On February 16, 2017, the Presidium of the Supreme Court of the Russian Federation approved the Review of Court Practice in the Consideration of Cases Involving the Application of Certain Provisions of Section V.1 and Article...more

Ratings – the road to revaluation

On 1 April 2017 the business rates revaluation will take effect. This in itself is cause for significant concern. However, the ratings world is currently a maelstrom of upheaval and controversy, such that the revaluation is...more

Tax Reform in 2017? What is in Store for U.S. Businesses

With Republicans in control of the White House and Congress, one of the top priorities is tax reform. President Trump’s tax reform proposal and the House Republicans’ tax reform “Blueprint” suggest many changes to business...more

Decision on Unitary Group Stands after Michigan Supreme Court Chooses Not to Review

On January 24, 2017, the Michigan Supreme Court denied the application filed by the Michigan Department of Treasury (the "Department") for leave to appeal the Court of Appeals' published decision in LaBelle Management v...more

Local Cannabis Regulation: Two Ballot Measures Up for Vote on March 7, 2017

This article examines the two competing ballot measures regarding cannabis regulation in the City of Los Angeles up for vote on March 7, 2017. Following is a brief summary of the current regulatory framework for cannabis in...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Capital gains not employment income for management participation returns

On October 4, 2016 the German Federal Fiscal Court (Bundesfinanzhof) delivered its decision in respect of matter number IX R 43/15. The decision was not published until January 25, 2017 but was eagerly awaited by, in...more

Your Daily Dose of Financial News

Former AIG chief Hank Greenberg and his co-defendant, AIG’s former CFO, reached an “unexpected” settlement last week with NY officials. The duo will fork over about $10 million in bonuses payments and admit that they...more

IRS Updates Golden Parachute Audit Guide

This is our first of many alerts during 2017 as the new administration signals the rollback of many regulations (e.g., fiduciary rules and pay ratio). We will keep you posted. In January 2017, the Internal Revenue...more

The Blockchain revolution: An analysis of regulation and technology related to Distributed Ledger Technologies

Blockchain is on the verge of revolutionizing how we interact in the digital world. It has far reaching applications from the Financial industry to many other sectors of the economy. The question is what is Blockchain, what...more

IRS Issues Final Regulations on REIT and RIC Conversion Transactions

The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing from ten years to five years the recognition period for the corporate-level tax...more

"Trump’s Proposed Changes to Tax, Dodd-Frank, DOL Could Impact Executive Compensation"

President Donald Trump’s campaign proposals included changes to tax rates and a promise to repeal the Dodd-Frank Act. If enacted, these proposals could have a significant impact on the way businesses handle executive...more

Safeguarding Your Company from Cyber Tax Crimes - Take Action Now!

As if tax season was not bad enough, the U.S. Internal Revenue Services ("IRS") recently issued an urgent alert warning that cybercriminal phishing scams are utilizing a new, more dangerously effective method for large-scale...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

Shareholder Liability For Corporate Income Tax?

Limited Liability - In general, the creditors of a corporation cannot recover the corporation’s debts from its shareholders—the shareholders enjoy the benefit of limited liability protection as a matter of state law....more

The New Issue Price Regulations: The Good, the Bad and the Ugly

Late last year, the Treasury Department released final Treasury Regulations (the “New Regulations”) relating to the “issue price” of tax-exempt bonds, effective for bonds sold after June 7, 2017. Because the changes imposed...more

South Carolina Court of Appeals, in Olds v. City of Goose Creek, Affirms Circuit Court Order Regarding Definition of Gross Income...

In Olds v. City of Goose Creek, 2016 S.C. App. LEXIS 147, the South Carolina Court of Appeals provides a thorough discussion of the application of the South Carolina business license tax to a taxpayer’s gross income. The...more

House Proposal for Border Adjustability and Relevant WTO Rules

On June 24, 2016, on behalf of the House Republican Caucus, House Speaker Paul Ryan, R -Wis., and House Ways and Means Chairman Kevin Brady, R -Tx., proposed sweeping reforms of the U .S. income and corporate taxes. The...more

IRS Issues Guidance on Tax Treatment of Energy Savings Performance Contracts

On January 19, 2017, the Internal Revenue Service (IRS) issued Rev. Proc. 2017-19, 2016-6 I.R.B. (the Rev. Proc.), providing a safe harbor under which it will not challenge the tax treatment of an Energy Savings Performance...more

Public Finance Advisory: IRS Releases Clarifying Management Contracts Rules

For the third time in as many years, the Internal Revenue Service (the “IRS”) has issued guidance for determining whether a management contract will result in private business use for property financed with governmental or...more

Brexit Update: UK as a Holding Company Hub

The United Kingdom is still an attractive location for a holding company, despite the uncertainty over Brexit. ...more

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

The (Border) Adjustment Bureau: Hold On to Your (Imported) Hats

Retailers would be wise to pay close attention to the upcoming tax-plan deliberations of the 115th U.S. Congress. A proposal currently being considered would adjust the U.S. corporate tax by making imports a non-deductible...more

Michigan Tax News - January 2017

Michigan’s 2017 property tax assessment notices are in the mail. Should you appeal? Local assessors are in the process of sending annual notices of real and personal property tax assessments to property owners/taxpayers,...more

Rolling Over Target Equity Into A PE Fund: Part I

For many business owners, the final step of a successful career may be the sale of their business. At that point, the investment into which the owners have dedicated so much time, effort and money is liquidated, leaving them...more

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