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Treasury Department and IRS Publish Final Hybrid Plan Regulations and Announce Extension of Required Amendment Date for Certain...

The Treasury Department and the IRS recently issued final regulations (the “2015 Final Regulations”) relating to hybrid retirement plans, including cash balance pension plans. The 2015 Final Regulations provide...more

The IRS Continues to Face Significant Budgetary Constraints—What Does It Mean To Taxpayers?

The Chief Financial Officer’s Act of 1990 (“1990 Act”) was signed into law by President George H.W. Bush on November 15, 1990. One of the major goals of the 1990 Act was to improve the financial management and to gain better...more

MoFo New York Tax Insights - Volume 6, Issue 11

Resident Is Not Subject to Use Tax on Yacht Briefly Docked in the State - In Matter of Michael Pellino, DTA No. 825869 (N.Y.S. Div. of Tax App., Oct. 1, 2015), a New York State Administrative Law Judge concluded that...more

"Congress Overhauls Partnership Audit and Litigation Procedures"

On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more

Conflating tax law and trust law: The strange case of Ciampa v. Bank of America.

Under the Internal Revenue Code, an Individual Retirement Account (IRA) may be a trust. See 26 U.S. Code § 408(a). Or it may be a custodianship. See sub-section (h) to §408. Here is sub-section (h) verbatim: FOR PURPOSES...more

By the Numbers: The Annual Report of the Division of Tax Appeals and Tax Appeals Tribunal

Earlier this month, the Annual Report of the New York State Division of Tax Appeals and Tax Appeals Tribunal for fiscal 2014-15 was submitted to the governor and the heads of the Senate and Assembly. Last year, we offered our...more

European Commission adopts first two decisions in EU tax probe in push for corporate tax reform

On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and...more

The European Commission’s New Pandora’s Box – Reopening Final Tax Rulings as a Form of “State Aid”

In Short - The European Commission (Commission) has adopted a decision on 21 October 2015 on the tax rulings – also referred to as “comfort letters” – granted by Luxembourg to Fiat Finance and Trade (FFT) and by The...more

IRS Limits Ability of REITs to Obtain Private Letter Rulings on Tax-Free Spin-Off Transactions

In the recently released Revenue Procedure 2015-43, the Internal Revenue Service (“IRS”) announced that it no longer will issue private letter rulings with respect to certain tax-free spin-offs where, immediately after the...more

Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

"IRS Implements Final Changes to Competent Authority Process"

On August 12, 2015, the IRS issued Rev. Proc. 2015-40, which revises the procedures for obtaining competent authority (CA) assistance concerning issues arising under U.S. income tax treaties. This revenue procedure replaces...more

MoFo New York Tax Insights - Volume 6, Issue 9

Tribunal Upholds Personal Liability of LLC Members for Sales Tax - The New York State Tax Appeals Tribunal has affirmed the determination of an Administrative Law Judge that a member of a limited liability company...more

Hard Hats Required: Sales Taxes & Capital Improvements - Some Practical Pointers

We recently authored an article in State Tax Notes analyzing New York’s complicated rules affecting sales taxation of contractor services and capital improvements. In this follow-up post, we want to highlight a few practical...more

Maybank on the Government Accounting Standards Board issued Statement No. 77, Tax Abatement Disclosures - Tax and Economic...

Today, August 15, 2015, the Government Accounting Standards Board issued Statement No. 77, Tax Abatement Disclosures. It will generate quite a bit of work for local government. In fact, it may force counties to organize...more

Altera: Tax Court Invalidates Section 482 Regulation on Administrative Law Grounds

In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm’s-length...more

Clean Power Plan Finalized by Obama Administration and EPA — What's Next?

On August 3, 2015, President Obama and the Environmental Protection Agency (EPA) released a new set of final regulations aimed at reducing carbon output from power plants. The sweeping new Clean Power Plan (CPP) sets limits...more

Energy Insights: An Update from the Second Quarter of 2015

In this edition of Seyfarth Shaw’s Energy Insights Newsletter our Energy and Clean Technologies team covers important developments in Q2 2015 for the energy industry including court protection for companies using hydraulic...more

The Advantages of Independent State Tax Tribunals

The following is an edited transcript of a discussion at a May 8 meeting of the American Bar Association Section of Taxation’s State and Local Taxes Committee in Washington. Bruce Ely, a partner at Bradley Arant Boult...more

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

ALJ Strikes Down Aggressive Attempt by New York State Department of Taxation and Finance to Tax Nonresident Attorney

An Administrative Law Judge (“ALJ”) with the New York State Division of Tax Appeals recently struck down an aggressive attempt by the New York State Department of Taxation and Finance (the “Department”) to tax the income of a...more

Alabama Department of Revenue Issues Controversial Proposed Regulation Taxing Out-of-State Vendors

Consistent with Governor Robert Bentley’s public statement last week that he hopes or another internet e-tailer will sue the state of Alabama regarding its position on nexus, the Alabama Department of Revenue...more

"Tax Court Invalidates Stock-Based Compensation Amendment in Altera"

On July 27, 2015, the U.S. Tax Court, in Altera Corp. and Subsidiaries v. Commissioner, 145 T.C. No. 3, invalidated a 2003 amendment to Treas. Reg. §1.482-7(d)(2) (2003 Amendment) that required controlled participants in a...more

Tax Court Refuses To Reweigh The Evidence, Affirming The Indiana Board Of Tax Review’s Final Determinations Of Land Value For A...

In a pair of related decisions issued July 2, 2015, the Indiana Tax Court once again emphasized that it will not reweigh the evidence on appeal from the final determinations of the Indiana Board of Tax Review....more

MoFo New York Tax Insights - Volume 6, Issue 7 - July 2015

In This Issue: - Important Changes at NYS and NYC Tax Agencies - Court of Appeals Upholds Constitutionality of Taxing Nonresidents on Gain from S Corporation Stock Sale in Two Separate Decisions - NYC Tribunal...more

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