Tax Business Organization

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
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It’s Time For 401(k) Plan Sponsors To Get A Grip

As an ERISA attorney with a national retirement plan practice, I often feel like a flight attendant giving the safety discussion on a commercial airplane. When I talk about retirement plans and fiduciary liability, I think...more

IRS Announces Proposed Partnership Audit Regulations Which Impact Limited Liability Companies and Partnerships

The Internal Revenue Service (IRS) has released Proposed Regulations under Section 1101 of the Bipartisan Budget Act of 2015 (BBA), which provide that for tax years beginning after December 31, 2017, all entities taxable as...more

Lawyers: Give your clients a business entity checkup

As we prepare for perhaps another round of major tax law changes, you might want to consider the status of your clients’ legal postures. Making a client’s business structure more nimble or setting the stage to obtain outside...more

Upheaval in the German Restructuring Market – Need-to-know Facts and Alternative Tools

To date, a debt waiver has been frequently used as a tool to successfully restructure German based companies in financial difficulties. A decision of the German Federal Fiscal Court (Bundesfinanzhof) published on...more

Ratings – the road to revaluation

On 1 April 2017 the business rates revaluation will take effect. This in itself is cause for significant concern. However, the ratings world is currently a maelstrom of upheaval and controversy, such that the revaluation is...more

German Supreme Tax Court Confirms Capital Income Qualification Under Management Equity Programs – Close to a Breakthrough, But…

The German Supreme Tax Court has confirmed that a close to “market standard” Management Equity Program will be taxed on capital income principles. The decision (court number IX R 43/15) provides comfort with respect to most...more

Tax Reform in 2017? What is in Store for U.S. Businesses

With Republicans in control of the White House and Congress, one of the top priorities is tax reform. President Trump’s tax reform proposal and the House Republicans’ tax reform “Blueprint” suggest many changes to business...more

Decision on Unitary Group Stands after Michigan Supreme Court Chooses Not to Review

On January 24, 2017, the Michigan Supreme Court denied the application filed by the Michigan Department of Treasury (the "Department") for leave to appeal the Court of Appeals' published decision in LaBelle Management v...more

Section 721(c) Partnership Regulations Arrive Just in Time

On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under Section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some...more

Are you in compliance with Colombia's transfer pricing rules?

Colombian law requires income taxpayers to file an informative return and supporting transfer pricing documentation in certain circumstances. The following summary will help determine if you or your business are required to...more

The IRS Targets Thirteen Issues in Its New Compliance Campaigns

On Tuesday, January 31, the IRS announced the rollout of thirteen initial compliance campaigns that will be undertaken by its Large Business and International Division (“LB&I”). These campaigns are part of a broader IRS...more

Trump Administrations Agenda affects Wealth Management

There’s little doubt that President Trump will carry through on the many promises that he made during the campaign that affect individuals, investors and advisors in the Wealth Management Industry. Corporations, too, were...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Keeping Your Company’s Data Safe This Tax Season

Tax-related identity theft is nothing new, but tax season 2016 took tax schemes to a new level. Last year, our cyber experts advised a large cluster of clients (public and private companies) over a period of only two...more

The Australian Government significantly expands ATO powers to fight multinational tax avoidance: Legislation introduced for 40 per...

Introduction and overview - The Australian Government introduced legislation (DPT legislation) into Parliament on 9 February 2017 to implement a further component (second limb) of the United Kingdom–style diverted...more

IRD consults on GST treatment of management fees and outsourced services

'Questions we've been asked' (QWBA) are statements issued by the Office of the Chief Tax Counsel of the New Zealand Inland Revenue Department (IRD) in response to queries received on specific tax issues which are likely to be...more

Ukraine and USA signs treaty on FATCA (Ukrainian)

On 7 February 2017, the Minister of Finance of Ukraine and the US Ambassador to Ukraine signed a treaty on Ukraine’s performance of the US Foreign Account Tax Compliance Act (FATCA) (the Treaty). According to the Ministry of...more

Birds-Eye View of New Gain Recognition Rules on Transfers of Appreciated Property to Partnerships with Related Foreign Partners

The IRS recently issued extensive regulations under the authority of Section 721(c) that denies nonrecognition treatment for transfer of appreciated property to a controlled partnership (domestic or foreign) by a U.S. person...more

Tax Planning in Uncertain Times

There is a long list of reforms that the Trump administration intends to tackle and one of the items on the list is tax reform. Although there are multiple proposals by various players and significant variations among the...more

Stretch out estate tax on business interests

Frequently, heirs of successful entrepreneurs are forced to sell off business interests at “fire sale” prices to help pay federal estate taxes. To alleviate the tax strain, Internal Revenue Code Section 6166 allows heirs to...more

CRA Releases New Guidelines Regarding Canadian Exploration Expenses

On the heels of some recent positive legislative changes regarding the tax treatment of environmental study and community consultation costs, the Canada Revenue Agency (CRA) has revised its administrative guidelines for the...more

Gone Phishing: IRS Warns Businesses of Tax Season W-2 Phishing Scam

Tax season is upon us, and as millions of people nationwide are preparing to file their tax returns, the Internal Revenue Services (IRS) has issued an urgent warning regarding a recurring e-mail phishing scheme targeting...more

Tax Filing Fraud

Tax returns and W-2s are information rich documents that contain the name and Social Security Number of an employee, as well as information concerning their salary and address, and personal behavior and characteristics (e.g.,...more

How a 401(k) Plan Sponsor Minimize Their Liability In 8 Easy Steps

Sponsoring and operating a 401(k) plan isn’t easy. A plan sponsor can’t just set up the plan and forget it. They need to constantly be on the watch because of the liability exposure they have as a plan sponsor. When plan...more

KNOWN UNKNOWNS about Federal Tax Laws and Regulations

The new administration in Washington, supported by Republican majorities in Congress, has pledged substantial changes to federal tax laws and regulations. One change may - or may not - be the complete elimination of federal...more

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