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IRS Proposed Tax Regulations Aimed at Fee Waiver Arrangements

The Treasury Department and the Internal Revenue Service have issued proposed regulations addressing disguised payment for services of a partner, including the proper tax treatment of fee waiver arrangements commonly used by...more

Goodwill and Section 1031 Exchanges Do Not Mix Well

The goodwill of a business can never be exchanged for the goodwill of another business. Goodwill is not like kind property. Treasury Regulation 1.1031(a)-2(c)(2) makes that crystal clear, providing: "The goodwill or...more

Abu Dhabi is 30 Per Cent More Attractive - Film Commission offers unique rebate to international production companies

The UAE is constantly seeking new and innovative ways to encourage business growth across the Emirates. Film and TV production is one of the diverse range of areas in which the Emirate of Abu Dhabi has actively looked to...more

ConAgra Brands; Taxpayer Loss in First Post-Gore Decision Signals More Challenges for Intercompany Transactions in Maryland

The Maryland Tax Court recently issued its decision in ConAgra Brands Inc. v. Comptroller of the Treasury, 09-IN-OO-0150 (Md. Tax Ct., Feb. 24, 2015). The case involved the Comptroller’s assertion of nexus over ConAgra...more

The New “Click-Through”?: New York Budget Proposal Requires Marketplace Providers to Collect Tax

On January 21, Governor Cuomo delivered his State of the State address, along with proposing the new budget. The budget has a number of new tax proposals. One of those proposals would have a significant impact on e-commerce...more

MoFo New York Tax Insights - Volume 6, Issue 1 - January 2015

In This Issue: - The Top 10 New York Tax Highlights of 2014 - Tribunal Affirms That a Charter Yacht Is Not Exempt from Use Tax as a Commercial Vessel - Court of Appeals Holds City Transfer Tax Does Not...more

Legal Alert: Court Holds Comcast Did Not Establish Unitary Relationship with QVC

Yesterday the Los Angeles Superior Court held that Comcast did not establish a unitary relationship with its 57% owned subsidiary, QVC. The court found for Comcast and held that the evidence presented at trial demonstrated...more

Internet Fundraising for Tax-Exempt Organizations

The IRS recently released an Information Letter, written in response to a congressman’s inquiry about an unidentified charity’s unidentified practices, confirming that Section 501(c)(3) organizations may use the internet to...more

The Top 10 Things That Every Business Owner Should Do At Year-End

As a business owner, all year you have likely been running around acting as manager, developer, business generator, marketer, human resource manager and administrative assistant. Given the numerous roles, it is often tough...more

PA Tax Law News -- September 2012

In This Issue: Online Advertising; PA Sales Tax Prepayment Option; State & Local Tax Seminars; PA School Districts Seek to Increase Property Taxes; Florida Domicile Upheld; Nonresident Limited Partners Lose Entire...more

Tri-State Tax Alert

From our offices in Boston, Portland, and Portsmouth, Pierce Atwood’s State and Local Tax Group provides litigation, planning, transaction, regulatory, and legislative services to business, associations, and individuals on...more

New Maine Tax Legislation for 2012

This year’s short legislative session produced significant new tax laws dealing with all of Maine’s major taxes, as well as increased legislative oversight of Maine Revenue and dynamic fiscal analysis. Below is a brief...more

10 Lessons from the Verizon Cases at the State Corporation Commission

In December of 2009, Verizon Communication, Inc.’s two “baby bell” subsidiaries in Virginia (Verizon Virginia, Inc. and Verizon South, Inc. — collectively, “Verizon”) filed applications to correct erroneous assessments of...more

Inside Maryland State Taxes: And the Saga Continues…Maryland Tax Court Hears New Intangible Holding Company Case

Last week, the Maryland Tax Court heard arguments in ConAgra Brands, Inc. v. Comptroller of the Treasury, No. 09-IN-OO-0150. ConAgra Brands is the most recent case in which the Comptroller has asserted nexus over an...more

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