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Internal Revenue Service Releases Notice Liberalizing the Private Business Use

On October 24, 2014, the Internal Revenue Service (“IRS”) released Notice 2014-67 (the “Notice”), providing guidance with respect to Accountable Care Organizations and their use of tax-exempt bond financed projects. The...more

IRS Releases Favorable Private Business Use Rules for Facilities Financed With Tax-Exempt Bonds

On October 24, 2014, the IRS released Notice 2014-67, which establishes more favorable safe harbors for types of service contracts and other arrangements using property financed with tax-exempt bonds. The Notice also provides...more

Notice 2014-67 ?? Safe Harbors for ACOs and a New Management Contract Safe Harbor for Everyone

On Friday, Oct. 24, 2014, the Internal Revenue Service released interim guidance, Notice 2014-67, on whether a state or local government entity or an organization described in §501(c)(3) of the Internal Revenue Code of 1986,...more

The Prospects for Corporate Tax Reform

As the 2014 midterm elections approach, speculation is widespread as to whether tax reform can be successfully pursued in 2015. The successful 1986 Tax Reform Act navigated through a politically divided Congress a full...more

IRS Releases Private Business Use Guidelines for ACO Participants

On Friday, October 24, 2014, the Internal Revenue Service (IRS) released Notice 2014-67, providing guidance regarding the circumstances under which participation by a hospital in an Accountable Care Organization (ACO) will...more

How to Pick Your Retirement Plan Providers

It’s easier to spend money than to make money. It’s easier to lose a client than get hired by a new one. As a retirement plan provider, you can ill-afford to lose clients. Too many retirement plan providers don’t see how...more

Retirement Plan Sponsors Should Know Their Role as Plan Fiduciaries

I love professional wrestling and I’m not afraid to admit. Yes, I know it’s not real just like I know the Ewings don’t live on Southfork Ranch. Maybe it’s in my blood since both of my grandfathers watch it, but I find 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

Take Advantage of Washington’s High-Tech Incentives before It’s Too Late!

Two significant Washington research and development tax incentives are set to expire on January 1, 2015: the High Technology B&O Tax Credit for qualified R&D expenditures (“High-Tech Credit”) and the High Technology Sales and...more

Sold Only an Interest in Your Property? Get Ready To Pay More Tax

California state and local government agencies looking for more revenue have long been looking at real estate sales to increase their tax take. Last month, the California Court of Appeal for the Second Appellate District...more

IRS Clarifies Requirements for Streamlined Filing Procedures

On October 9, 2014, the Internal Revenue Service published additional guidance clarifying the requirements for participation in the Streamlined Filing Compliance Procedures. (See prior coverage of the new procedures...more

Recent New Jersey Tax Court Decision Creates Income Tax Refund Opportunity

In the recently decided case PPL Electric Utilities Corp. v. Director, Drinker Biddle was successful in convincing the New Jersey Tax Court that neither the Pennsylvania capital stock tax nor the gross receipts tax are...more

Doing Business in Australia

With strong economic fundamentals, a positive outlook, proximity and strong trade links with some of the world’s most dynamic economies, Australia offers a wealth of opportunities for global investors and multinational...more

Lies That Prospective Retirement Plan Providers May Tell You

When we were children, our mothers told us stories that we believed to be true because we always believed what our parents were telling us was the truth. Part of growing up is realizing that a good chunk of what your mom told...more

Blog: Has The PCAOB Finally Reached A Compromise On Naming Audit Engagement Partners?

The saga of the PCAOB and its proposals to require identification of the audit engagement partner continues. Compliance Week reports, based on a newly published PCAOB standard-setting agenda, that the PCAOB is now...more

MoFo New York Tax Insights - Volume 5, Issue 10 - October 2014

In This Issue: - State Tribunal Reverses ALJ and Allows Combined Reporting - Tribunal Finds Oxygen Cylinders Were Purchased for Resale - Appellate Court Denies Nassau County Class Action Certification in...more

Disregarded Entity May Select Different Accounting Method than its Owner

In a recent Chief Counsel Advice (“CCA”), the IRS determined that a disregarded entity for federal income tax purposes (the “LLC”) operated a separate and distinct trade or business from that of its owner (the “Company”) and...more

Blog: So You Owe Thousands of Dollars in Delaware Franchise Tax?

All Delaware corporations have to pay an annual franchise tax to the state. If you’ve received a notice from the State of Delaware saying that your small startup owes tens of thousands of dollars in franchise tax, do not...more

Planning For The Exit – What’s Your Exit Strategy? [Video]

Cox Smith, Padgett Stratemann, and Navidar Group hosted an interactive discussion on the current climate for buying and selling businesses, preparations for you and your business, tax strategies, and the legal process behind...more

Who Runs my Joint Venture?

One of the primary purposes of a written partnership (or limited liability company (LLC) operating) agreement is to establish rights and obligations for management. In a general partnership or joint venture, any partner or...more

Perspectives - Trends and topics in not-for-profit management - September 2014

In this Issue: - Not-for-Profit Volunteers: HIPAA Compliance & Training - Not-for-Profit Spotlight: Project Sunshine - 10 Ways to Lose Your Not-for-Profit Status - Economic Development...more

Escaping Taxes in Bankruptcy Through S Corporations

Shareholders of financially troubled S corporations may now be able to avoid the flow-through of taxes when the S corporation or its subsidiary files bankruptcy. ...more

What Questions CEOs and Board Members Should Be Asking Themselves About Tax Inversions [Video]

Partner and Chair of BakerHostetler's Tax Group, Paul Schmidt, discusses tax inversions. What CEOs and Board of Directors should be asking themselves?...more

U.S. Treasury Department Takes Action to Slow (But Not Stop) Corporate Inversions: A Summary for Executives

What is an inversion? An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more

ESOPs: The Tax Law Provides a Buyer for Your Business

As baby boomer business owners begin to retire, many will want to monetize the value they have created in their businesses. An employee stock ownership plan (ESOP) is one alternative. The ESOP alternative, authorized by the...more

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