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

The Wrong Reasons For Hiring 401(k) Plan Providers

by Ary Rosenbaum on

Selecting a retirement plan provider can be a lot like dating in the sense that plan sponsors shouldn’t pick providers for the wrong reasons. Nobody knows more about the wrong reasons for dating more than me; we call those...more

ATO wins Full Federal Court decision on Cross Border Financing - Chevron Australia Holdings case

by DLA Piper on

In a major Australian transfer pricing decision on Friday 21 April 2017, the Full Federal Court dismissed Chevron Australia Holdings Pty Ltd's (CAHPL) appeal related to the deductibility of interest on the Australian dollar...more

Extensions to the double tax treaty passport scheme

by DLA Piper on

The double tax treaty passport (DTTP) scheme was introduced in 2010 as a mechanism to simplify the process by which non-UK lenders could receive interest payments from UK borrowers without deduction for withholding tax under...more

Trump Administration Releases Tax Reform Framework

by Ropes & Gray LLP on

On April 26, 2017, the Trump Administration announced several key tax reform proposals. Broadly resembling the Trump campaign platform, the proposals furnish only a high-level aspirational framework for wide-ranging reforms,...more

Trump Administration Announces Outline of Its Tax Proposal

by Proskauer - Tax Talks on

Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump’s original tax reform proposal announced during the campaign and of the House Republicans’...more

Trump Administration Releases Blueprint of Tax Reform

by Williams Mullen on

On April 26, 2017, the Trump Administration announced a blueprint of tax reform principles that is described as “The Biggest Individual and Business Tax Cut In American History.” The Administration identified four goals for...more

Using an S corporation to avoid self-employment tax

by Thompson Coburn LLP on

Our last post discussed self-employment (SE) tax and taxpayers’ efforts to avoid that tax when using an entity taxed as a partnership to conduct business. It concluded that a limited partnership that conducted business...more

Treating Partners as Employees – Overview and Update

by Ballard Spahr LLP on

Limited liability companies (LLCs) have become the fastest-growing entity choice for businesses in recent years. LLCs provide flexibility in operations and distributions. However, to the surprise of many businesspeople, if an...more

Audit Chances

by Pessin Katz Law, P.A. on

As in the past, PK Law reports on the Internal Revenue Service’s (“IRS”) data book (IR 2017-69) regarding a taxpayer’s chances of undergoing an audit. The annual data book reflects data collected during the fiscal year 2016...more

IRS Releases May 2017 Federal Interest Rates

by Bryan Cave on

The 7520 rate for May 2017 has decreased to 2.4%. The May 2017 Applicable Federal Interest Rates can be found here. Please see full Table below for more information....more

We Need a License To . . . Be a Charity?

by Ward and Smith, P.A. on

Wait a minute! Haven't we done everything we're supposed to do? We've clearly defined our charitable mission. We formed our non-profit corporation. We got our 501(c)(3) determination letter from the Internal Revenue Service...more

Drafting In The Details

by Dickinson Wright on

The Fifth Circuit Court of Appeals recently affirmed that the devil really is in the details in a case that illustrates the importance of ensuring that deal documents accurately reflect the parties’ agreed upon terms with...more

IRS Releases Updated Automatic Changes in Methods of Accounting List

On April 19, 2017, the Internal Revenue Service (IRS) released Rev. Proc. 2017-30, 2017-17 I.R.B. 1, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev....more

IRS Announces Disagreement with Ninth Circuit’s Holding on Completed Contract Method of Accounting

by Miles & Stockbridge P.C. on

The IRS recently announced its disagreement with the Ninth Circuit’s ruling that, with respect to planned communities, the 95% test under the completed contract method of accounting applies on a development-wide basis rather...more

Legal and Tax Conversions: Changing Your Company Structure Without Changing Your Company

by Varnum LLP on

Do you remember talking with your co-founders, your attorney and your accountant about what type of entity you should choose for your new company? And all of that discussion about limited liability, governance structure,...more

Get Over The Fear Of Hiring An ERISA Attorney

by Ary Rosenbaum on

As an attorney, I’ve heard a lot of lawyer jokes and some of them are amusing. I once said at law school that I now know why lawyers have terrible reputations because I met some of these lawyers at law school. While lawyers...more

China updates special tax adjustment measures: new rules go into effect May 1

by DLA Piper on

China's State Administration of Taxation (SAT) has released the Administrative Measures on Special Tax Investigation Adjustments and Mutual Agreement Procedures in the Public Notice [2017] No. 6 (Bulletin 6). Bulletin...more

Unexpected Risks of Early Exercise ISOs

by Dorsey & Whitney LLP on

Companies that permit the grant of early exercise incentive stock options (“ISOs”) do so primarily to limit the impact of the alternative minimum tax (“AMT”). However, due to fairly counterintuitive tax regulations,...more

IRS Releases 2017 Section 45 Production Tax Credit Amounts

On April 12, 2017, the Internal Revenue Service (IRS) published the 2017 inflation-adjustment factors and reference prices used in the calculation of renewable energy production tax credits under IRC section 45. That guidance...more

Jimmy Chen Seminar Attendees and Clients at Risk of Being Investigated for Tax Evasion

by Moskowitz LLP on

This past summer, Jimmy J. Chen, accountant and promoter of private charitable foundations, was charged with six felony counts of tax evasion. From 2009 through 2011, Mr. Chen apparently used his tax-exempt ChenSung Family...more

Turning Tides

by DLA Piper on

Ukraine is typically seen as an emerging country, blighted by crisis. Ukrainians are all gradually helping to change this stereotype. Here we examine key legal reforms aimed at improving the efficiency and safety of...more

Dutch Supreme Court refers questions on withholding tax refunds for foreign investment funds to CJEU

by DLA Piper on

The Dutch Supreme Court has referred preliminary questions on Dutch dividend withholding tax refunds for foreign investment funds to the Court of Justice of the European Union (CJEU). The Dutch Supreme Court wishes to clarify...more

CA Court of Appeal’s Split Decision Upholds CARB Cap-and-Trade Program

by Perkins Coie on

In a 2-1 decision, the California Court of Appeal, Third Appellate District, upheld the California Air Resource Board’s cap-and-trade program for greenhouse gas allowances. California Chamber of Commerce v. State Air...more

IRS Issues Guidance on “Placed in Service" Date for Retail Stores

by Miles & Stockbridge P.C. on

The IRS recently announced its disagreement with the ruling of the U.S. District Court for the Western District of Louisiana, that a retail store building could be considered “placed in service” before the retail store was...more

Two Important New International Tax Filings

by Charles (Chuck) Rubin on

While not the only international reporting changes that are occurring, there are two significant ones that apply for the current filing season for 2016 returns. First is the FBAR, which reports interests in foreign...more

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