Consulting Payments To A Related Entity Did Not Avoid Unreasonable Compensation Issues by Charles (Chuck) Rubin on 5/23/2012 An accounting firm operated as a C corporation. The firm paid substantial fees to three related entities created by the founding shareholders of the firm. The fees were so high as to reduce the net income of the firm to a de...more
Reuters: Corporations Face Long Odds in Tax Cases Heard by the United States Supreme Court – Situation Brighter in Canada by Fraser Milner Casgrain LLP on 5/21/2012 Reuters recently reported a study showing that corporations face very long odds in tax appeals heard by the United States Supreme Court. There were 919 income tax cases in the Supreme Court of the United States from 1909 to...more
Need More Than One Taxpayer Identification Number–Too Bad For You! by Charles (Chuck) Rubin on 5/21/2012 Taxpayers are requiring to have a taxpayer identification number to file returns and provide to payors, so that their tax data can be adequately tracked and reported. While most U.S. individuals will use their social security...more
Nuts and Bolts of Limited Partnerships by Doron Eghbali on 5/17/2012 Limited Partnerships are one of the forms of entities available to form in California. Limited Partnership offers limited partners limited liability to the extent of their investment in the business. Nonetheless, Limited...more
Breaking the Code of ERISA Fiduciaries: A Plan Sponsor’s Guide by The Rosenbaum Law Firm P.C. on 5/17/2012 When you are purchasing a home computer these days, it can often be confusing if you are not well versed in the jargon. While selecting between a Mac and a PC or a laptop vs. a desktop is easy, the other details can be...more
IRS Issues New Guidance to Private Foundations on Program Related Investments by Sheppard Mullin Richter & Hampton LLP on 5/16/2012 The IRS recently issued proposed regulations that provide new examples that illustrate what types of investments qualify as "program-related investments" (PRIs). These new examples are based on published guidance and on...more
UK Procedure on Unique Taxpayer Reference Numbers (UTRs) for Investment Partnerships Finalised by Proskauer Rose LLP on 5/16/2012 In 2009, Her Majesty's Revenue & Customs ("HMRC") in the UK announced that, for partnerships filing UK tax returns, each partner was required to have a unique taxpayer reference number ("UTR"). This primarily affected...more
King County Tax Amnesty by Davis Wright Tremaine LLP on 5/15/2012 Complying with every applicable tax law can be a daunting obligation even for a taxpayer well versed in tax rules. For start-ups, the task can be more than daunting when the taxing authorities do not tell you about your...more
Tax: Recent News Highlights - Montenegro by Karanovic & Nikolic Law Office on 5/14/2012 I. Amendments to the Law on Corporate Income Tax (page 2) The duration of the tax exemption period for investment in underdeveloped regions has been extended (page 2) — Certificates of tax residency finally introduced...more
Procrastination on Estate Planning Can Land A Small Business in Probate Court by Frank Brunetti on 5/14/2012 Procrastination on Estate Planning Can Land A Small Business in Probate Court By Frank L. Brunetti on May 14th, 2012 Many business owners hope that the companies they have built will outlive them and help build a...more
A Third “Last” Chance to Disclose Income from Foreign Accounts to the IRS by Armstrong Teasdale LLP on 5/14/2012 In January 2012, the Internal Revenue Service (“IRS”) announced its third Offshore Voluntary Disclosure Program (“OVDP”) aimed at U.S. taxpayers who have failed to report income from foreign accounts. Under the OVDP,...more
Proposed Regulations Offer New Examples of Program-Related Investments by Morgan Lewis on 5/11/2012 New examples describe additional charitable purposes and investment structures for PRIs. The Internal Revenue Service (IRS) and the Treasury Department have issued long-awaited proposed Treasury Regulations providing...more
How ESOPs Can Be Beneficial for Construction Companies by Sedgwick LLP on 5/10/2012 What Is an ESOP? First and foremost, an ESOP is an employee benefit plan that is qualified for tax-favored treatment under the Internal Revenue Code of 1986, as amended (IRC). However, an ESOP can also be a tool of...more
"Purely Public Charities" in Pennsylvania. Back to the future – again. by Saul Ewing LLP on 5/10/2012 A recent Pennsylvania Supreme Court decision has rekindled the issue of what constitutes a "purely public charity" for real estate tax exemption purposes in Pennsylvania. The decision may lead to a renewed interest of school...more
FCA affirms the importance of GAAP in computing liability for LCT rejecting the Crown’s economic substance argument by Fraser Milner Casgrain LLP on 5/9/2012 The Federal Court of Appeal has once again affirmed the importance of Generally Accepted Account Principles (GAAP) in computing liability for the large corporation tax (LCT) applicable prior to 2006 while rejecting the...more