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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

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

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

Favorable German tax regime for partnership-type AIFs expanded

The German Federal Ministry of Finance has recently issued guidance that broadens the favorable tax regime for investment partnerships applicable to closed-end alternative investment funds (AIFs). The following Dechert...more

Tax Policy Update

NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance...more

State and Local Taxation: Headline News and Trends

In This Presentation: - Megatrends and Developments - Business Activity Taxes - Transaction Taxes - Other Issues - Excerpt from Megatrends and Developments: PRIVATE LAWSUITS. CHOOSE...more

How to Mess Up Your Start-Up

There are lots of good articles out there about how to succeed.  Here are a few pointers on how to mess up your company from a legal perspective.  - Pick a name without checking it out. You may not be the first one to...more

France extends tax consolidation regime to horizontal groups

France’s Amended Finance Act for 2014, dated 29 December 2014, includes provisions extending the scope of the French tax consolidation regime to "horizontal" tax consolidated groups (i.e. tax consolidation between sister or...more

In California We Trust: A Sensible Expansion Of The Voluntary Disclosure Program

Trusts administered outside California often are susceptible to not filing California income tax returns. This is because California has an atypical legal threshold for filing: trusts must file if a trustee or beneficiary...more

An Overview of the Delaware Limited Liability Company Act

Delaware’s reputation as the premier jurisdiction for corporate entities is well known. In recent years, however, Delaware has also emerged as a leader in providing cutting-edge alternatives to the traditional corporate form....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

Five Changes to the Tennessee Nonprofit Corporation Act That You Need to Know

The following are five important changes to the Tennessee Nonprofit Corporation Act (the Act) which became effective January 1, 2015: 1. Affirmative Disclosure Requirement to Report Up the Chain of Command; 2....more

Lau: BC SC Corrects Articles of Incorporation After $17.3 Million Reassessment

Many tax rectification cases address situations in which certain transaction documents contain errors that do not accord with the parties’ intent to minimize or avoid taxes. However, there are several cases in which the...more

Tax Law Extension Good News for Non-corporate Investors

Congress once again temporarily extends the 100 percent capital gains exclusion on “qualified small business stock.” On December 19, 2014, President Obama signed the Tax Increase Prevention Act of 2014 (the 2014 TIPA)...more

Why Am I Taxed Now on My Future Receipts: The Woes of a Profits Interest

Companies often grant stock options to incentivize employees and so that their interests are aligned with the future success of the company, and partnerships (and limited liability companies taxed as partnerships) are no...more

"Are You Prepared for the Rapidly Approaching Abandoned Property Deadlines?"

Winter is right around the corner. For businesses that have abandoned property on their books (and virtually every operating entity has abandoned property, whether it knows it or not), that means due diligence letters must...more

Judge Rules Against FTB In “Doing Business” Definition

Over a year ago, I wrote about an Iowa corporation, Swart Enterprises, Inc., which operates a 60 acre farm in Kansas. Swart has no physical presence in California. It owns no real or personal property in California. However,...more

IRS provides interim guidance for ACO participation in Medicare Shared Savings Programs and expands safe harbors for management...

On October 24, 2014, the IRS published Notice 2014-67, which expands the Revenue Procedure 97-13 safe harbors regarding management contracts and further provides interim guidance related to a health care organization’s...more

Cashing Out of a Partnership – The Joy of Distributions

While partners usually groan upon receiving capital calls, they are delighted to receive distribution checks. However, provisions regarding distributions can be convoluted and require more than perfunctory consideration. Any...more

Qualifying for 501(c)(3) Tax Exempt Status is Tricky

The entities in the following IRS Technical Advice Memorandum and Private Letter Rulings failed to qualify for tax exempt status because they were not operated exclusively for exempt purposes. An organization must be...more

IRS Releases Guidance on Private Business Use, and ACOs and Management Contracts

On October 25, 2014, the Internal Revenue Service (the IRS) released Notice 2014-67 that provides interim guidance on (i) participation in the Medicare Shared Savings Program through an accountable care organization (ACO) and...more

Business Succession Planning — You Should Have Started Yesterday

You have worked incredibly hard and sacrificed a lot to build your business. No doubt that everyday concerns relating to your business take priority. However, failing to plan for the future can derail all that you have worked...more

Making The Right Choice For Your Business Entity

It has been said that plans are nothing, but planning is everything. Nowhere is this truer than in selecting the most appropriate legal entity for your new business....more

Comment Period Begins for VA Tax Guidelines for Pass-Through Entity Withholding

On October 28, 2014, the Department published draft guidelines for Pass-Through Entity Withholding. These guidelines are now available on the Department’s Guidelines for Pass-Through Entity Withholding website. ...more

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