Tax Updates

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Treasury Department Circular 230 Disclaimer Eliminated Form 2848 Incorporates Circular 230

Practitioners should remove any reference to a Circular 230 or IRS requirement in disclaimers sent with any written correspondence. The IRS Office of Professional Responsibility (OPR) may issue letters to some practitioners...more

Worker Classification Litigation on the Rise — An Analysis of the Ninth Circuit’s FedEx Case and Its Lessons for Tax Practitioners

Abraham Lincoln reportedly asked, ‘‘If you call a dog’s tail a leg, how many legs does a dog have?’’ His answer was, ‘‘Four. Calling a dog’s tail a leg does not make it a leg.’’ Similarly, when businesses classify workers,...more

Release of Draft British Columbia LNG Income Tax Legislation

In the 2014 provincial budget, the British Columbia government announced its intention to introduce income tax legislation later in the year applicable to the LNG industry (the LNG Income Tax). The B.C. government stated that...more

Southeast State & Local Tax: Important Developments - September/October 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA - INDIVIDUAL INCOME TAX...more

Prevailing Party Awarded Taxable Costs from Production to Opposing Party (California)

Apple Inc. v. Samsung, 2014 WL 4745933 (N.D. Cal. Sept. 19, 2014). In this intellectual property case, the plaintiff sought to recover around $1.5 million in costs for producing documents to an online hosted repository,...more

Tax Law Blog: 2015 Retirement Plan Limits Announced

Every year, about this time, the IRS calculates the cost of living increases, and determines whether the change is enough to trigger an adjustment to the statutory limit/threshold for various areas, including retirement...more

Arms’ Length Sale of Contaminated Property is Best Indicator of Value for Tax Appeal Purposes

In a recent Appellate Division decision (Orient Way Corp. v. Tp. of Lyndhurst), the Tax Court’s prior determination that an arms’ length sale of the subject contaminated property provided credible evidence of true market...more

Spotlight on Tennessee: Ruling Highlights Importance of State Income Tax Considerations for Section 338 Elections

In Spotlight on Tennessee: Letter Ruling Addresses Treatment of a Section 338(h)(10) Election, dated July 10, 2014, we examined how Tennessee treats the federal election under Internal Revenue Code Section 338(h)(10) for...more

Guide To Doing Business in New Zealand: Taxation

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

Another Tax Trap for the Unwary – Tax Court and the Blank Receipt

As a general rule, the fair market value of property contributed to charity is deductible in determining taxable income. However, deduction is contingent on the donor’s substantiating the fact and value of the property...more

IRS Announces 2015 Cost-of-Living Increases to Benefit Plan Limits

On October 23, 2014, the Internal Revenue Service announced cost of living adjustments affecting the limitations applicable to pension and other retirement plans, in IR 2014-99. Some of the limitations remain unchanged...more

Federal Tax Lien Did Not Survive Death of Joint Tenant

Two individuals (Cunning and Wren) acquired real property in the U.S. Virgin Islands as joint tenants with rights of survivorship (JTWROS) in 2005. In 2010 the IRS filed a federal tax lien against Cunning in the U.S. Virgin...more

Death of the “Double Irish Dutch Sandwich”? Not so Fast.

On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning...more

Sale-leasebacks accommodate buyer and seller in today’s healthcare real estate market: 7 reasons why they work, 5 pitfalls to note

For many years, low interest rates allowed companies with strong credit ratings to obtain access to cheap capital through traditional financing methods – meaning there was little enthusiasm for sale-leaseback...more

The 2015 Retirement Plan Limits are in

The Internal Revenue Service (IRS) announced cost of living adjustments affecting dollar limitations for pension plans and other retirement-related items for tax year 2015. The elective deferral (contribution) limit...more

Upcoming Nationwide Transfer Pricing Investigation Against Outbound Service Fee And Royalty Payments

On 29 July 2014, the China State Administration of Taxation (SAT) released an internal notice to the China tax authorities at the provincial levels, in the name of "Notice on Antiavoidance Investigation against Large Amount...more

Employer Reimbursement of Employee’s Individual Medical Insurance May Subject Employer to Penalty

IRS Notice 2013-54 provides that an employer’s reimbursement of healthcare insurance premiums paid by an employee on an individual health insurance contract of the employee on a pre-tax basis (an “employer payment plan”) may...more

Beneficial Owner Disclosure and Its Potential Impact on Global Financial Businesses

As part of the continued international focus on combatting cross-border tax evasion and other financial crimes, during the June 2013 Lough Erne Summit presided over by the United Kingdom (G8 Summit), the G8 countries agreed...more

New IRS Appeals Procedures Complicate Tax Dispute Resolution

This article describes and evaluates the new IRS Appeals Office policy for handling IRS audit appeals. This new policy is known as the Appeals Judicial Approach and Culture (“AJAC”) Project. The stated goals of the AJAC...more

A New Special Tax Adjustment Monitoring And Administrative Measure

Advanced Alert and Voluntary Tax Adjustment - The SAT released a short bulletin named "The Announcement on Issues Related to Special Tax Adjustment Monitoring and Administration" (SAT Bulletin [2014] No. 54 Bulletin...more

A Tax Incentive for Oregon’s Artists to Donate Their Work

Oregon tax law, unlike federal tax law, gives an incentive to Oregon resident artists to donate their own artwork to charities. In general, when an artist donates her art, and has obtained an appraisal, she can deduct the...more

California (Finally) Conforms to Federal Treatment of UBTI in Charitable Remainder Trusts

One of the most important tax attributes of charitable remainder trusts is that they are exempt from income tax – except, that is, when it comes to unrelated business taxable income (UBTI) of these trusts. For decades the...more

Employee Share Scheme Rules Overhaul

AS FORESHADOWED IN OUR RECENT ARTICLES (4 AUGUST AND 8 OCTOBER), THE FEDERAL GOVERNMENT HAS NOW COMMITTED TO: (A) REVERSING (AT LEAST IN PART) THE CONTROVERSIAL EMPLOYEE SHARE SCHEMES TAX CHANGES IMPLEMENTED IN 2009 AND (B)...more

2015 COLAs for Employee Benefit Plans

The Internal Revenue Service has announced the 2015 cost of living adjustments to various limits on employee benefit plans. The adjusted amounts generally apply for plan years beginning in 2015. Some of the adjusted amounts,...more

Affordable Care Act in Mergers and Acquisitions: New Guidance from Internal Revenue Service

In Notice 2014-49, the Internal Revenue Service (“Service”) issued guidance on how to avoid potential penalties under the Affordable Care Act (“ACA”) in connection with mergers and acquisitions (“M&A”). The notice provides a...more

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