Tax Updates

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
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IRS Releases Highly Anticipated Cash Balance Plan Regulations

The U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently released long-awaited final regulations (the Final Regulations) with respect to market rates of return and related Pension Protection...more

Pension News - September 2014

Welcome to DLA Piper’s Pensions News publication in which we report on recent developments in pensions legislation, guidance and case law, as well as keeping you up to speed on what to look out for in the coming months....more

New Scottish property transaction tax: Highest rate band for commercial property announced as 4.5%

John Swinney, the Scottish government's Finance Secretary, has announced the proposed rates and bands for the new Scottish property transaction tax known as the Land and Buildings Transaction Tax (LBTT). On 1 April...more

Estate Planning Pitfall: Watch out for IRA traps

An IRA can be a valuable estate planning tool, offering tax-deferred growth (tax-free in the case of a Roth IRA) and asset protection. But two recent developments create traps for the unwary: the “one-rollover-per-year” rule...more

Qualified Domestic Trust (QDOT) Frequently Asked Questions

When an international couple comes into our office to plan their estate, they often have a lot of questions about qualified domestic trusts (QDOTs) – especially if they own a significant amount of property or assets. Below,...more

Proposed Approach for Applying the “Look-Back” Method When the Section 4980H Measurement Period Changes

The Internal Revenue Service (IRS) recently issued Notice 2014-49 which describes a proposed approach for determining an employee’s full-time or part-time status for purposes of the employer shared responsibility rules under...more

IRS Proposes Key Changes to Schedule H's Community Health Needs Assessment and Financial Assistance Policy Questionss

On October 8, 2014, the IRS released drafts of the 2014 Form 990, Schedule H and Instructions, proposing significant changes related to a hospital facility's compliance with Section 501(r) of the Internal Revenue Code. These...more

Tax Court Strikes Down “DAD” Loss Importation Tax Shelter

In consolidated cases known as Kenna Trading LLC, the Tax Court shut down an attempt to contribute foreign currency losses into a US partnership and syndicate the losses to investors by selling partnership interests followed...more

New Jersey Refund Opportunities Associated with the Deductibility of Other States’ Taxes

On October 2, in PPL Electric Utilities Corporation v. Director, Division of Taxation, No. 000005-2011, the New Jersey Tax Court determined that federal deductions for the taxpayer’s payments of Pennsylvania gross receipts...more

Outstanding Design Flaws in California’s Cap-and-Trade Program

On January 1, 2013, California embarked on a grand experiment with the launch of the world’s most complex cap-and-trade program. Under this program, companies operating in California, such as food processors, power producers...more

Good intentions: Don’t let asset transfers run afoul of the law

With the current estate tax regime of a high gift and estate tax exemption amount and low estate tax rates, transferring wealth is becoming the focus of estate planning rather than reducing estate tax liability. And with...more

IRS Issues Final and Proposed Hybrid Plan Regulations

On September 19, 2014, the Internal Revenue Service ("IRS") released additional final regulations clarifying the rules regarding hybrid defined benefit pension plans. At the same time, the IRS also issued proposed regulations...more

B.C. Supreme Court Rescinds Land Transfers

In Re 0741508 BC Ltd and 0768723 BC Ltd (2014 BCSC 1791), the British Columbia Supreme Court (“BCSC”) considered whether rescission should be granted in respect of two real estate transactions in which the applicant...more

IRS Modifies Offshore Filing Procedures

The IRS has issued FAQs relating to the new streamlined procedures for offshore compliance, and for Delinquent International Information Return Submission Procedures....more

Tax Lessons from Reality Stars on What Not to Do

Two reality stars recently made headlines for being prosecuted for tax crimes and fraud. In both cases, the reality stars surely knew that consequences were coming: one was the subject of an IRS criminal investigation, and...more

Fall 2014 Municipal Revaluations in Connecticut

A number of Connecticut municipalities (see list at the end of this alert) plan to conduct revaluations effective October 1, 2014. For those with commercial real property located in one of the communities on the list,...more

Court Weighs in on Deadline for Filing FTC Refund Claims

On September 19, 2014, the U.S. Court of Federal Claims issued its opinion in Albemarle Corp. v. United States, No. 12-184T, holding that it lacked jurisdiction over the taxpayer’s claim for refunds based on foreign tax...more

Inside M&A - Fall 2014

Managing Compliance Risks in M&A Transactions - Buyers can acquire unintended and potentially very damaging liabilities together with target business or assets. Analyzing the financial situation of a target company,...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 11: Rethinking ACA Compliance Strategies Involving Reference...

Under the Affordable Care Act’s rules governing employer shared responsibility—which are codified in Internal Revenue Code § 4980H—where an applicable large employer makes an offer of group health plan coverage that is both...more

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part 3 - Inbound Investment Real...

As an undergraduate at West Point, I was a Spanish and Portuguese major. My Brazilian “thing” had already started a decade earlier as a ten year old growing up in the Panama Canal Zone seeing Pele play for his Brazilian team...more

How to Pick Your Retirement Plan Providers

Too often, retirement plan providers are selected at the family dinner table, the golf outing, or a house of worship. While those are nice places for social gatherings, they are not the ideal place for selecting plan...more

Massachusetts Tax Developments: A Reed Smith Quarterly Update (3rd Quarter 2014)

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look back to the developments from the first half of 2014, and look ahead to market-based sourcing and other issues on the...more

Court of Appeal Holds Transfer Tax Applies to Legal Entity Changes in Ownership

In 926 North Ardmore Avenue, LLC v. County of Los Angeles, the 2nd District Court of Appeal held that Proposition 13 changes in ownership prompted by transfers of legal entity interests should also be characterized as “realty...more

IRS Announces Impending Tighter Enforcement of Employer-Provided Meals, Fringe Benefits

Internal Revenue Code § 119 allows employers to deduct 100% of the value of meals provided to employees when they are for the convenience of the employer, and they are furnished on the business premises of the employer. Meals...more

Beware of Tax Phishing Scams

We have recently become aware (again) of fake emails purporting to emanate from the CRA and informing the recipient that he/she has received an Interac email money transfer (i.e., a surprise refund). Generally, the...more

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