Tax General Business

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Only the Lonely: “Lonely” Life Insurance Companies Confront New Issues Under Proposed Debt-Equity Regulations

The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal...more

Is it Debt or is it Not? Proposed Treasury Regulations Would Significantly Change Debt vs. Equity Analysis

Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the “Proposed Regulations”) under Section 385 of the Internal Revenue Code. The Proposed Regulations would significantly modify the tax...more

New Proposed Regulations Increase Scrutiny on Related-Party Debt

The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more

Update on The Panama Papers

The International Consortium of Investigative Journalists (ICIJ) announced that on May 9, it will release selected data purported to be leaked or stolen from the internal records of the Panamanian law firm Mossack Fonseca....more

Tom Brady’s suspension reinstated, so what are the potential Massachusetts tax consequences?

Deflategate and the NFL’s suspension of quarterback Tom Brady for 4 games has been the NFL’s biggest news story of the past two years. On April 25, 2016, the United States Court of Appeals for the Second Circuit ruled in...more

Obligation to Perform Work and Incur Costs Under Construction Contract is a Section 752 Liability

In a recently issued Private Letter Ruling (PLR 201608001), the IRS determined that a taxpayer-partnership’s obligation to perform work and incur costs under a long-term construction contract constituted a partnership...more

NJ Tax Court Denies Interest Addback Exception - Does Your Company Still Qualify?

In a decision published April 26, 2016, the New Jersey Tax Court in Kraft Foods Global Inc. v. Director, Div. of Taxation ruled that a taxpayer couldn’t deduct interest paid to its corporate parent. The taxpayer’s...more

IRS Reverses Position on “Bad Boy” Guarantees

Earlier this year, the IRS issued Chief Counsel Advice 201606027 (February 5, 2016) concluding that, for purposes of the basis and at-risk limitations, an LLC member’s guarantee of entity-level nonrecourse debt conditioned...more

Changes to IRS Partnership and LLC Audit Rules

Recent history has seen a proliferation of health care organizations—including tax-exempt organizations, for-profit companies, and physician practice groups—that have joined together to take advantage of different synergies...more

Economic Nexus Extended Too Far – Hodgson Russ LLP v. Minnesota Department of Revenue

During the spring of 2014, Hodgson Russ LLP (“Hodgson”) received a letter from the Minnesota Department of Revenue (“Minnesota Revenue”) that attempted to establish a new low in the states’ “race to the bottom” to establish...more

Your daily dose of financial news The Brief – 4.21.16

Dealbook’s White Collar Watch gives us a legal take on the many challenges, regulatory and otherwise, facing Elizabeth Holmes’ Theranos – NYTimes... The international financial scandal du jour (the Panama Papers) is...more

Proposed IRS and Treasury Regulations Have Broad Implications for Intercompany Debt Structures

On April 4, 2016, the U.S. Treasury Department and the Internal Revenue Service (“IRS”) issued proposed regulations ostensibly aimed at curbing inversions and earnings stripping, by companies located in the U.S. with overseas...more

Vermont Proposes Colorado-style Use Tax Reporting Law

As we discussed in February, the Tenth Circuit upheld the constitutionality of Colorado’s use tax notification law with its decision in Direct Marketing Association v. Brohl (DMA II). In his concurrence to the decision, Judge...more

China Customs authorities enhance monitoring of intercompany prices and royalty payments

China’s General Administration of Customs (GAC) has released an amendment to the Import and Export Declaration Documents Standards. Among many changes, the Amendment now requires Chinese entities with importing and exporting...more

The Panama Papers: Managing Corporate Risk and Uncertainty

On April 3, 2016, it became public that an anonymous source had leaked 11 million confidential documents, known as the “Panama Papers,” belonging to the Panama-headquartered international law firm Mossack Fonseca. As more of...more

Trade in the balance: Europe's new Union Customs Code

The European Union — the world's largest trader of manufactured goods and services — is adopting a new framework of customs rules, the Union Customs Code (UCC). From cutting-edge California mobile devices and Chinese...more

The Panama Papers: Taking a New Look at an Old Problem

On April 3, 2016, the International Consortium of Investigative Journalists (“ICIJ”) published more than 11.5 million documents connected to Mossack Fonseca, a Panama law firm that helped establish offshore financial...more

UK Financial Regulatory Developments - April 2016 #13

FCA finalises guidance on sharing SME credit information - FCA has published its finalised guidance on Small and Medium Sized Business (Credit Information) Regulations. This follows Treasury’s designation of the banks...more

Spotlight on Tennessee: Department of Revenue's Upcoming April 26 Rulemaking Hearing

On April 26, 2016, at 1:00 p.m. CST, a hearing will be conducted regarding proposed regulations filed by the Tennessee Department of Revenue (Department) with the Secretary of State on February 25, 2016. This rulemaking...more

U.S. Tax Implications of Offshore Migration of Intellectual Property

Challenges of Transferring IP Offshore - What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights,...more

Panama Papers: Looking Below the Headlines

The media loves a scandal. In the banking and compliance world, the latest scandal to hit the media was the Panama Papers. The Panama Papers is surprising in scope – Panama has become the favorite financial haven for money...more

The Global Spotlight on Transparency: Renewed Focus on Tax and Financial Regulatory Enforcement in Singapore

The global spotlight on transparency in tax and financial reporting has come to Singapore, signalling cause for renewed focus on compliance for investors and global business operators. On 6 April, the Singaporean Ministry of...more

International Tax Advisory: New Temporary Regulations Continue the Fight Against Inversions

On April 4, the Treasury released temporary regulations to attack (and prevent) inversions. Aimed at transactions designed to avoid the purposes of Sections 7874 and 367 and certain post-inversion avoidance transactions, the...more

Early Stage Investment Tax Incentives Bill Introduced

As an update to our Legal Insight of December 2015 'New Tax Incentives for Early Stage Investment', on 16 March 2016 the Turnbull Government introduced legislation providing significant tax incentives to promote local and...more

Navigating the Louisiana Legislature's New Sales and Use Tax Labyrinth

Not even Daedalus could have constructed a labyrinth more complex than the new sales and use tax laws that the Louisiana Legislature adopted in the 2016 First Extraordinary Session that ended on March 9, 2016. Perhaps on a...more

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