Tax General Business

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
News & Analysis as of

Supreme Court Decides Direct Mktg. Ass'n. v. Brohl

On March 3, 2015, the Supreme Court decided Direct Mktg. Ass’n. v. Brohl, No. 13-1032, holding that the Tax Injunction Act (TIA), which provides that federal district courts “shall not enjoin, suspend or restrain the...more

All Nine Agree: U.S. Supreme Court Holds that the Tax Injunction Act Does Not Bar DMA’s Action in Federal Court

Yesterday the U.S. Supreme Court unanimously held in Direct Marketing Ass’n v. Brohl that the Tax Injunction Act (TIA) does not bar Direct Marketing Association’s federal lawsuit against Colorado.1 The TIA provides that...more

Don’t Miss Short-Term Deferral Day

Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.”...more

Welcome Tax Measures Announced at the PDAC 2015 Convention

On Sunday March 1, 2015, the Honourable Joe Oliver, Federal Minister of Finance addressed the Prospectors & Developers Association of Canada (“PDAC”) at the annual PDAC Convention in Toronto and announced certain proposals...more

Two Key Alabama Business Associations Announce Their 2015 State Tax Legislative Agendas

In preparation for the 2015 regular session of the Alabama Legislature, which begins Tuesday, March 3, one of Alabama’s most influential business and trade organizations, the 5,000-member Business Council of Alabama (BCA),...more

Insigh: Capital Markets: Tips for Taps

Following a successful bond issuance, an issuer may consider a “tap” issuance as a way to access further funding. White & Case offers some “Tips for Taps” for issuers and underwriters in accessing the capital markets...more

Inside the New York Budget Bill: Guidance Released Regarding Transitional Compliance and Qualified New York Manufacturers

On March 31, 2014, Governor Andrew Cuomo signed into law a budget bill containing major corporate tax reform. That new law resulted in significant changes for many corporate taxpayers, including a complete repeal of Article...more

Taxpayer Loses Related-Party 1031 Exchange Case Involving Heavy Equipment

On Monday, the Eighth Circuit Court of Appeals issued its decision in North Central Rental & Leasing, LLC vs. U.S., holding that North Central Rental & Leasing, LLC (“Taxpayer”) had improperly excluded gain in a purported...more

Pennsylvania Goes to Market: State Applies Source Taxation All the Way Home

On December 12, 2014, the Pennsylvania Department of Revenue (DOR) issued Information Notice Corporation Taxes 2014-1 (Notice). The Notice provides guidance for taxpayers in understanding Pennsylvania’s new market-based...more

European Competition Law Newsletter – March 2015

A recent European Commission (EC) fining decision against UK-based broker ICAP confirms that companies which merely facilitate a cartel will be tarred with the same brush as those which actually engage in the cartel. The...more

Relief from the BEIP Freeze?

Unexpected relief may be coming for companies that are owed millions in unpaid incentive grants from New Jersey. The Business Employment Incentive Program (known as BEIP) provided companies with grants of up to 80% of...more

Tips and Traps Regarding the Statute of Limitations and Signing Statute Waivers

As you end your telephone conversation with the revenue examiner, you think to yourself, “Thank goodness, this one is finally over!” The audit of your biggest client started over three years ago, and has seemingly dragged on...more

The Timing of E&P to US Parent Corporations of CFCs

The earnings and profits (E&P) of a corporation dictate the income tax treatment of non-liquidating distributions it makes to its shareholders. Distributions from a corporation to the extent of its current or accumulated E&P...more

Under the Dome: Inside the Maine State House

Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. Public Hearings on Governor’s Tax Reform Proposal Complete - This week, the Appropriations...more

IRS Releases First Private Letter Ruling on Small Redemption Limitation

On October 21, 2013, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued Final Treasury Regulations to provide relief under Section 382 for small redemptions. These regulations provide taxpayer...more

IRS Issues Private Letter Ruling on Treatment of Managed Professional Corporations

The Internal Revenue Service (“IRS”) recently published a private letter ruling (“PLR”) that permits a practice management corporation to include two managed professional corporations as members of the management...more

Japan: Significant Changes In Consumption Tax

Raise in Consumption Tax Rate Postponed - On November 18, 2014, Shinzo Abe, the Japanese Prime Minister, officially announced that the increase of the consumption tax rate which was originally planned to occur in October...more

Highlights from the Toronto Centre CRA & Professionals Group Breakfast Seminar – February 19, 2015

On February 19, 2015, at the Toronto Centre CRA & Professionals Group Breakfast Seminar CRA representatives provided an update on two topics: 1) online CRA e-services, and 2) Regulation 102 and Regulation 105 waivers for...more

IRS Clarification on Non-Willful Conduct Certification for Streamlined Offshore Compliance Procedures: Revisions to IRS Forms...

Many U.S taxpayers are often surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their obligation, there are a number of programs through...more

IRS Private Letter Ruling Provides Tax Planning Opportunities for Healthcare Companies

The IRS recently issued PLR 201451009, providing that a management services company and two professional corporations (PCs) were members of the same affiliated group under Section 1504(a) of the Internal Revenue Code...more

Fifth Circuit Holds that Loss on Abandoned Securities is Ordinary Loss

Wednesday, the Fifth Circuit issued its decision in Pilgrim’s Pride and held that a loss on abandoned securities is ordinary. The Fifth Circuit rejected the IRS’s argument that Section 1234A and Section 165(g) apply to treat...more

5th Circuit Allows Ordinary Loss for Stock Abandonment

Wednesday, the 5th circuit reversed the Tax Court and held in Pilgrim’s Pride that a taxpayer could receive an ordinary loss on the abandonment of a stock interest....more

Hong Kong Government to Extend Existing Offshore Funds Tax Exemption to Private Equity Funds

The Hong Kong government has announced in its latest budget a planned extension of the existing offshore funds tax exemption to bring offshore private equity funds investing in or through Hong Kong, within its scope. The...more

Tax Policy Update

NUMBER OF THE WEEK: $160,000. The value of one gift bag at the Oscars on Sunday night. According to the Internal Revenue Service, contents of the gift bags cannot be treated as gifts for federal income tax purposes because...more

Accountant and Attorney Liability Newsbrief - Winter 2015

In This Issue: - The Affordable Care Act and CPAs: It Takes a Village - U.S. District Court for District of Massachusetts Holds Testator’s Attorney Can Be Held Liable to A Beneficiary - New Jersey...more

2,568 Results
|
View per page
Page: of 103

Follow Tax Updates on: