Tax Updates

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
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Do As We Say, Not As We Do: Audit Reveals Unencrypted IRS Emails Put Taxpayer Data at Risk

With tax season around the corner, the Internal Revenue Service (IRS) has begun its yearly campaign to educate taxpayers on the importance of protecting their personal information. However, a recent audit of the agency’s...more

Did You Make the Multistate Tax Compact Apportionment Election in California? Watch Out for Penalties

On December 31, 2015, the California Supreme Court ruled against the taxpayer in The Gillette Company v. Franchise Tax Board. The United States Supreme Court denied review of Gillette on October 11, 2016. Thus, Gillette is...more

Burden of Proof Issues in Gift Tax Matter

A recent case illustrates 3 important burden of proof issues. The general facts of the case involved a merger of a company owned by parents with a company owned by children. The gift tax issue involved the relative value...more

California Cities To Tax Streaming Video?

Many cities in California are considering the expansion of their Utility User Tax (UUT) to streaming video services. Such an expansion may be inconsistent with the cities’ existing ordinances, be invalid under Proposition 218...more

MoFo New York Tax Insights - Volume 7, Issue 12

NYC ALJ Holds That Consulting Firm May Source Receipts Based on Location of Independent Contractors - The nature of the services performed by a corporation, and how that corporation should source its receipts from those...more

Dollar Financial UK Ltd v HMRC: When Must a Financial Intermediary Charge VAT?

Executive Summary - The decision in Dollar Financial UK Ltd v HMRC [2016] UKFTT 598 will likely be of interest to a range of participants in the lending market, and the financial services sector more generally, because...more

FATCA and CRS: 2016 Year End Reminders and a Look Ahead to 2017

As 2016 comes to a close, U.S. FATCA is almost fully phased-in, U.K. FATCA is being phased-out and the Common Reporting Standard (“CRS”) is nearing the first anniversary of its effective date. What began as a concept in 2010...more

Personal Tax and Estate Planning Considerations for the End of 2016

The end of the year is always a good time for our clients to look at their personal tax and estate planning situation and consider whether to take any action before Dec. 31. This year, with the Trump administration about to...more

A “Crystal Ball” On Life After The New ERISA Fiduciary Rule

The Department of Labor’s (DOL) new fiduciary rule that is going to go in effect in April 2017 is going to have a profound change in how financial advisors work with their retirement plan clients. It’s unchartered waters,...more

Developments in Association Law 2015–2016

The Nonprofit Organizations Practice at Pillsbury has prepared this summary of significant legal and policy developments that have occurred in approximately the past year. All of these developments have potential impacts upon...more

Employers Need To Be Aware Of Potential Pitfalls Of Providing Opt-Out Incentives To Company Health Insurance

In recent proposed regulations, the Internal Revenue Service (IRS) addressed how the Affordable Care Act (ACA) impacts the use of employer opt-out incentives, which are payments to employees who decline an employer’s group...more

The ERISA Litigation Newsletter - November 2016

This month we review a recent Second Circuit decision addressing ERISA plan status as a class member in a securities shareholder class action. As discussed in the article, the decision exposes a potential conflict among the...more

Impact Investing and Private Foundations

Bryan Cave recently organized a half-day symposium examining the opportunities and legal considerations related to responsible and impact investing strategies. The Responsible and Impact Investing Symposium, held on November...more

IRS and Treasury Issue Proposed Regulations Easing Some of the Burden of the Fractions Rule

Executive Summary On November 22, the Internal Revenue Service (“IRS”) and Treasury Department issued proposed regulations (REG-136978-12, the “Proposed Regulations”) under the “fractions rule” of Section 514(c)(9)(E) of the...more

IRS Announces Additional Procedure for Accepting Late Retirement Plan Rollovers

The Internal Revenue Code (IRC) provides that distributions from certain retirement arrangements (e.g., qualified retirement plans, individual retirement accounts (IRAs), §403(a) annuity plans, §403(b) tax-sheltered...more

Deadline for Providing Affordable Care Act Statements Has Been Extended

The IRS has extended the deadline by 30 days for providing individuals the 2016 Form 1095-B and Form 1095-C. The new deadline for the individual forms is now March 2, 2017 instead of January 31, 2017....more

Expansion of US disclosure requirements will impact foreign investors – the future of money laundering and tax enforcement

The United States is turning its attention to activities by foreign investors who use US trusts, limited liability entities, and other investment structures to conceal the ownership of criminal proceeds or foreign tax...more

Major changes in the Polish VAT regulations as of 1 January 2017

On 16 November 2016 the Sejm (lower chamber of the Parliament) adopted a bill to amend the VAT Act and certain other statutory laws, calling for numerous changes in the VAT Act and the Criminal Fiscal Code, among other laws....more

Autumn Statement – Greening Public Finance

The Autumn Statement (the Statement) highlighted sustainability of public finance as key to securing a strong and stable economy for the UK. The need to prioritise longer-term sustainability schemes over short-term economic...more

Navigating the ACA in the Trump Era

On November 8, 2016, the future of the Patient Protection and Affordable Care Act (ACA) became more uncertain. Republicans in Congress have been working to repeal the ACA since it was passed in 2010, and now, with control of...more

Taxes and Divorce

Divorce is tough. Even amicable divorces are financially and emotionally draining. The last thing you need is to have tax problems pop up as a result of divorce proceedings. To avoid such problems here’s a list of some top...more

IRS Proposes Helpful Changes to "Fractions Rule" Tax Regulations

Proposed income tax regulations published by the Internal Revenue Service (IRS) on Nov. 23, 2016, amend the current regulations regarding the application of the "fractions rule" to partnerships that hold debt-financed real...more

IRS Grants Extension of ACA Information Reporting Deadline and Provides Good Faith Standards for 2016 Information Reports

The IRS recently issued Notice 2016-70, which extends certain 2017 deadlines for employer information reporting under the Affordable Care Act (ACA) on health coverage offered to individuals during the 2016 calendar year. The...more

Employee Benefits Developments - November 2016

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of November, 2016. ACA Information Reporting – Bad News and Good News - First, the bad news: The 2016 final...more

Employment Matters – UK - November 2016

Autumn Statement – Employment Issues The Chancellor has issued an autumn statement setting out certain proposed fiscal changes in the UK. One of these is to the Employee Shareholder Status (ESS) regime, which is set to...more

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