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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

New Sales Tax Exemption for Georgia Fine Arts Non-Profits

by Taylor English Duma LLP on

On August 21, 2017, the Georgia Department of Revenue released Policy Bulletin SUT-2017-07 providing a sales tax exemption for sales of tickets, fees, or charges for admission to certain fine arts performances or exhibitions...more

The Plan Providers That A 401(k) Plan Sponsor Needs

by Ary Rosenbaum on

When an employer decides to start a 401(k) plan, one of the biggest problems out there is that they don’t know who they need. They know that they need someone to help on their retirement plan, but they don’t know who. One of...more

Tax Court Holds That Foreign Corporation’s Sale Of A Partnership Interest Not Taxable In US

by Cole Schotz on

The US Tax Court recently held that a foreign corporation is not subject to US income tax on the sale of a partnership interest where the partnership conducts a US business. In so holding, the Tax Court rejected a 26 year...more

IRS Seeks Applications for Advisory Committee for the Tax Exempt and Government Entities Division

by Bryan Cave on

The IRS is seeking applicants for vacancies on the Advisory Committee on Tax Exempt and Government Entities (ACT). The committee provides advice and public input on the various areas of tax administration served by the Tax...more

AFRICA - A Legal Guide for Business Investment and Expansion: Zimbabwe

1 .What role does the government of Zimbabwe play in approving and regulating foreign direct investment? The Government established the Zimbabwe Investment Authority (ZIA) to promote, coordinate and approve investment...more

IRS Issues Guidance on Stock/Cash Dividends for REITs and RICs

On August 11, 2017, the Internal Revenue Service released guidance allowing publicly offered real estate investment trusts and regulated investment companies to distribute earnings in a combination of cash and stock as long...more

New Tax Court Decision Provides Planning Opportunities for Foreign Investors Investing in U.S. Partnerships

by Mintz Levin on

On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more

CA Supreme Court: Entity Ownership Change Can Trigger Documentary Transfer Tax

Many entities are formed for the sole purpose of buying and holding real estate. In this setup, legal title is held by the entity itself (not the entity’s owners), but the entity’s owners have a “beneficial interest” that...more

The Corporate Offences of Failure to Prevent the Facilitation of Tax Evasion – What It Means for You

by Reed Smith on

The United Kingdom’s Criminal Finances Act 2017 (the “Act”) creates two new corporate offences of failure to prevent facilitation of tax evasion (the “Corporate Offences”). These new Corporate Offences will be committed where...more

Not a Token Gesture: Compensating Service Providers with Virtual Property

by Morrison & Foerster LLP on

Questions surrounding the use of virtual currencies and other digital tokens (“tokens”) as compensation came to the forefront last month following formal guidance from the U.S. Securities and Exchange Commission (“SEC”) on...more

U.S. Withholding on Synthetic Trades over U.S. Equities—Further Delay of Full Implementation Until 2019 (Notice 2017-42)

In response to perceived abuses in taxpayers’ use of swaps and other derivative transactions (e.g., options, futures or forwards) to avoid withholding tax on U.S. source dividends, Congress added Section 871(m) to the...more

IRS Provides Guidance on Stock Distributions for Publicly Offered REITs and RICs

by Latham & Watkins LLP on

Revenue procedure sets forth requirements for ensuring certain stock distributions are treated as property distributions eligible for dividends paid deduction. On August 11, 2017, the Internal Revenue Service (IRS)...more

Loans to U.S. Subsidiaries Should Be Carefully Structured and Documented to Obtain U.S. Tax Benefits

by Dorsey & Whitney LLP on

Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity...more

AFRICA - A Legal Guide for Business Investment and Expansion: Tunisia

1. What role does the government of Tunisia play in approving and regulating foreign direct investment? The Tunisian government places a priority on attracting foreign direct investment. The Tunisian government...more

U.S. Tax Court Ruling Exempts Gain on Foreign Partner's Sale of a Partnership Interest

by Foley & Lardner LLP on

On July 13, 2017, the U.S. Tax Court issued a decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S....more

Clues That There are Problems With A 401(k) Plan Provider

by Ary Rosenbaum on

When it comes to illnesses and diseases, there are usually warning signs out there. Whether you can come out healthy from a debilitating illness or disease is dependent on whether you can tell the warning signs. I’ve seen...more

Developments in the U.S. Tax Treatment of UK Charities

by DLA Piper on

The Internal Revenue Service has revoked the U.S. tax exempt status of 195 prominent UK charities by posting their names on a website. These UK charities will find it harder to attract support from U.S. individuals and...more

Ireland's Revenue releases guidelines on requesting Mutual Agreement Procedure assistance

by DLA Piper on

Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as...more

Tax Talk: Volume 10, Issue 2

by Morrison & Foerster LLP on

EDITOR’S NOTE - With the failure of health care legislation to “repeal and replace” the Affordable Care Act, eyes in Washington, D.C. are now turning to tax reform. Since Congress plans to take August off, any real tax...more

AFRICA - A Legal Guide for Business Investment and Expansion: Tanzania

1 .What role does the government of the United Republic of Tanzania play in approving and regulating foreign direct investment? The government plays an active role in approving and regulating foreign direct investment....more

New partnership audit rules can apply to partnerships, LLCs with only a few partners, members

by Thompson Coburn LLP on

Effective in 2018, changes in partnership audit rules may apply the following (and other) consequences to partnerships (including LLCs taxed as such)...more

Tax Court Holds that IRS Cancellation of Advance Pricing Agreement was Abuse of Discretion

by King & Spalding on

On July 26, 2017, the Tax Court issued its opinion in Eaton Corp. v. Commissioner, holding that the IRS’s cancellation of two advance pricing agreements (“APAs”) reached with Eaton Corporation (“Eaton”) was “arbitrary and...more

Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest

by McDermott Will & Emery on

In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more

AFRICA - A Legal Guide for Business Investment and Expansion: South Africa

1 .What role does the government of South Africa play in approving and regulating foreign direct investment? South Africa is a constitutional democracy and an active member of the international investment community. It...more

Growing Concerns with Proposed Amendments Affecting Private Businesses and their Shareholders

by Bennett Jones LLP on

On July 18, 2017, Minister of Finance Bill Morneau announced sweeping changes to the way private businesses and their shareholders are taxed. The Government's proposals encompass three broad areas: (1) income sprinkling...more

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