Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
Selling Privately Held Businesses – Interview with Stephen Gulotta, Managing Member, Mintz Levin's New York Office
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk
Hot Topics for Waste-to-Energy Investors and Developers
Monitor Thy Drink: Alcohol Import Regulations Under the TTB (Alcohol and Tobacco Tax and Trade Bureau)
Corporate Law Report: Workplace Romances, FMLA Changes, California Tax News, and More
The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate Insights
Will The Debt Ceiling Standoff End Up In Court?
Corporate Law Report - Office Party Holiday Risks, Human Trafficking, the Fiscal Cliff, More
Micah Green on U.S. Fiscal Policy
How Do We Pay For Lower Corp Tax Rates?
Polsinelli Shughart Election Analysis and Legal Insight
Why choose Bennett Jones for your Canadian Cross-Border Income Trust (CBIT)?
What are the tax benefits of a Canadian Cross-Border Income Trust (CBIT)?
Why choose Canada for a Cross-Border Income Trust (CBIT)?
What is a Canadian Cross-Border Income Trust (CBIT)?
Bill on Bankruptcy: Solyndra, Lehman, MF Global, ATP Oil, LSP Energy, Want Ads
Should you Opt-Out of the Voluntary Disclosure Program?
Weekly Brief: CFPB, Legal Fees & Hashtag Hijackers
Cost of Voluntry Asset Disclosure Program
The Chancellor of the Exchequer today delivered a 130-page Autumn Statement that contained a number of surprises, as well as expected updates on areas such as partnership taxation....more
In Wendy’s International, Inc. v. Brian Hamer, decided earlier this week, the Illinois Appellate Court found that Taxpayer had met its burden and proved that its subsidiary insurance company was a bona fide insurance company...more
Pennsylvania insurers should be aware that proposed changes to Pennsylvania’s Insurance Holding Company regulations impose significant new requirements – especially for management agreements, service contracts, tax allocation...more
Life insurance and irrevocable trusts are great tools to ease family business succession issues and mitigate exposure to shareholder oppression and disputes. Irrevocable life insurance trusts (ILIT), in particular, play an...more
For good reason, much of the focus for Arizona contractors during the recently-concluded legislative session was on transaction privilege tax (TPT) reform. That bill, HB 2111, was ultimately signed by the Governor, but only...more
I. FLORIDA STATE CASES - ILAN NIEUCHOWICZ & SASHA FUNK GRANAI -
Ad Valorem Taxes: presumption that assessment correct lost in ad valorem tax challenge where taxpayer proves by preponderance of evidence either (i)...more
On September 4, the United States Tax Court issued its opinion in Acuity v. Commissioner, T.C. Memo. 2013-209. In brief, the court concluded that Acuity’s reserves for unpaid losses and loss adjustment expenses for 2006, as...more
A decision by the United StatesCourt of Appeals for the Second Circuit earlier this month strictly interpreted deductibility I.R.C. § 808(c) as it relates to the deductibility of policyholder dividends paid by life insurance...more
On August 1, 2013, the U.S. Court of Appeals for the Second Circuit held in New York Life Ins. Co. v. U.S., that the taxpayer’s liability for policyholder dividends was contingent, and therefore, was not deductible until the...more
In This Issue:
Making the ‘Right’ Choice; Top Ten Mistakes Businesses Make Regarding Insurance; and You’ve Got the Job, Details Will Follow.
Excerpt from Making the ‘Right’ Choice -
You have the idea, you...more
In This Issue:
- NEW METHODS FOR NOTIFYING THE TAX REGISTER OF DATA CONCERNING CONTRACTS AND INSURANCE PREMIUMS – ITALIAN INLAND REVENUE MEASURES NO. 51770/2013 OF 30 APRIL 2013
- ILLEGAL DATA EXCHANGE AMONG...more
The respective purposes of the New Markets Tax Credit Program (NMTC) and the Low-Income Housing Tax Credit Program (LIHTC) are entirely complementary. ...more
A recent California appellate decision (In Re Insurance Installment Fee Cases, 211 Cal. App. 4th 1395) held that an installment fee – i.e, a fee charged to a policyholder who pays premium in installments under a payment plan...more
This article discusses the use of private placement products - private placement deferred variable annuities (PPVA) and private placement life insurance (PPLI)- in post mortem income tax and transfer tax...more
On April 16, 2013, the Senate Finance Committee held a hearing on “Tax Fraud and Tax ID Theft: Moving Forward With Solutions,” including testimony on proposals to restrict access to the Social Security Administration’s Death...more
On April 10, the Obama Administration released its fiscal year 2014 budget (FY 2014 Budget). Of note, the FY 2014 Budget includes a number of tax proposals that target insurance companies or that otherwise would have a direct...more
High net worth and income taxpayers find themselves in a world of hurt following tax reform at the end of 2012. The top marginal bracket for taxpayers with more than $400,000 (single and $450,000 married)...more
We end the first month of the year with a report on major insurance topics that we will be watching in 2013.
Many of these developments can be traced to discrete events or market or political forces. This year, those...more
In This Issue:
- President Opposes Medical Device Tax Repeal or Replace
- Senators Call for Extension of Comment Period on ACA Proposed Rules
- AHA Urges U.S. District Court to Expedite Case Involving CMS' Payment...more
On December 5, 2012, the Internal Revenue Service (IRS) published final regulations regarding the implementation of the excise tax applicable to the sale of certain medical devices, enacted by the Patient Protection and...more
The Internal Revenue Service (IRS) released final regulations and other guidance on the excise tax applicable to the sale of certain medical devices under the Affordable Care Act. Beginning January 1, 2013, a tax of 2.3...more
Life insurance policies can be great vehicles for income tax deferral. Part of this arises from the fact that earnings growth that occurs inside the policy is not subject to current income tax (and may never be taxed if the...more
Many small and mid-size businesses in New York City suffered severe losses due to Hurricane Sandy. Below is a practical guide for business owners seeking relief.
- The first place business owners...more
In my last installment, I discussed the benefits of a private placement insurance contract (life insurance or annuity) issued by a life insurer domiciled in Puerto Rico – Isla del Encanto – for Americans living...more
Corporate owned life insurance assets (COLI) and Bank owned life insurance (BOLI) assets may account for close to $1 trillion or more of life insurance company assets. Virtually every major public corporation uses COLI. Why?...more