Tax Business Organization

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Business Appraisers Spar Over Tax Rates, Market Approach and Other Key Issues in Fair Value Buy-Out Case

As promised in the postscript to last week’s post about the appellate ruling in the Gould case, affirming Justice Platkin’s order granting the oppressed minority shareholder’s dissolution petition involving a pair...more

The New Partnership Audit Rules Are Coming, Have You Checked Your Operating Agreement?

At the end of 2015, the Bipartisan Budget Act of 2015, as amended (the “BBA”), was enacted into law, and will be effective for tax years beginning after 2017. Under the BBA, the rules relating to the audit of partnership tax...more

When A “Tax Free” Exchange May Not Be Free of Tax

“Tax free” – two words that often bring great delight when they are spoken by a tax adviser to the owner of a business, whether he is considering the disposition of a single asset, or of substantially all of the assets, of...more

Mental Impairment as a Defense to Civil Penalties

There are severe penalties under the Internal Revenue Code (IRC) and Bank Secrecy Act (BSA) for willful failure to file Information Returns. Examples of Information Return are Report of Foreign Bank Account (FBAR) required...more

Report a Canadian Tax Evader and Make Money?

Yes, it's possible. Canada has had a tax whistleblower program for four years, the Offshore Tax Informant Program (OTIP). The OTIP pays individuals who qualify for the program and provide information to the Canada Revenue...more

Singapore Eases Regulatory Regime for VC Funds to Promote Financing for Start-Ups

The Monetary Authority of Singapore has proposed a simplification of the authorisation process and regulatory framework for venture capital managers—with the goal of supporting start-ups....more

When Will a Canadian Corporation be Treated as a Passive Foreign Investment Company?

A Canadian corporation will generally be a passive foreign investment company or “PFIC” if, for a tax year, (a) 75% or more of its gross income is passive income (the “PFIC income test”) or (b) 50% or more of the value of its...more

EU member states reached consensus on anti-hybrid mismatch measures

On February 21, 2017, the Council of the European Union (ECOFIN, in this context) reached political consensus on a directive (known as ATAD 2) amending the EU Anti-Tax Avoidance Directive as adopted on July 17, 2016 (EU...more

Practice Pointers: Anticipating and Addressing SEC Comments on Non-GAAP Financial Measures - February 2017

The use of non-GAAP financial measures by public companies continues to be an area of growing concern for the Securities and Exchange Commission (“SEC”). Since the staff of the SEC’s Division of Corporation Finance (the...more

Just When We Thought Measure 97 Was Dead—It May Be Back!

As I reported previously, Oregon Measure 97 was overwhelmingly defeated by voters in the state’s general election this past November. It certainly appeared that the voters spoke loudly and clearly on November 8, 2016, when...more

EO Update: e-News for Charities & Nonprofits

IRS makes approved Form 1023-EZ data available online - The IRS announced today that publicly available information from approved applications for tax-exemption using Form 1023-EZ, Streamlined Application for...more

BEPS – are you affected?

Over 100 countries and jurisdictions are collaborating through the OECD to implement measures to tackle base erosion and profit shifting (BEPS). The OECD have set out 15 actions points that aim to equip governments with the...more

Senegal's new Mining Code

In October 2016, the Senegalese Parliament passed a new Mining Code (the New Mining Code), which affects the way mining permits are processed, places additional social and environmental obligations on mine operators and...more

Why an Employer Should Sponsor A 401(k) Plan

As an employer, a big reason for setting up a retirement plan is because it’s an employee benefit and it can be used to recruit and retain top-level employees. Unlike health insurance, the costs of running a retirement plan...more

Distressed M&A faces new tax challenge - German supreme tax court judged tax relief for recapitalization gain illegal

The German Tax Authorities' common instrument to grant relief from an taxable recapitalization gain - the Recapitalization Decree (Sanierungserlass) - violates constitutional rights according to a recent decision of the...more

LB&I to Closely Scrutinize Basket Transactions

The Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced its first 13 issue-based campaigns on January 31, 2017. As discussed in a prior Eversheds Sutherland Legal Alert, these...more

Foreign Investment in Australia

Foreign investment is key to Australia’s economic development, and Australia welcomes it. As the fourth largest economy in the dynamic Asia Pacific region, Australia's competitive economy is set for continued expansion...more

Ukraine: New rules on withholding tax for Eurobond offerings and LPNs

Starting from January 1, 2017 Ukrainian tax legislation contains new (more favorable) rules on taxation of interest payable by Ukrainian borrowers under Eurobonds offerings relating to LPN structures. It is common for...more

N.Y.’s 2018 Budget Proposal: Tax Proposals To Watch

Last month, Governor Cuomo presented his budget proposal for NY State’s 2017- 2018 fiscal year. Included in the proposal were a number of tax provisions that should be of interest to closely-held businesses and their owners....more

Luxembourg CSSF Circular 17/650 - Primary tax offences - In the fight against money laundering, what are your professional...

On 17 February 2017, Luxembourg’s financial regulator (Commission de Surveillance du Secteur Financier – CSSF) issued a circular drawn up with the Financial Intelligence Unit in order to provide...more

Georgia Tax Tribunal Issues Two New Decisions on Remote Seller Nexus and Georgia Tax Credit Elections

The Georgia Tax Tribunal, in its first published decisions in more than a year, held that: (1) Scholastic Book Clubs has nexus in Georgia and must collect sales tax; and (2) a taxpayer’s election of one tax credit for...more

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

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