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Key Takeaways From Delaware’s Unclaimed Property Overhaul

A bill has been introduced in the Delaware Senate that would overhaul Delaware’s unclaimed property law. The bill is on a fast track and could be enacted by the end of January. If enacted, companies currently under audit will...more

Boozelaw: TTB Adopts Changes Designed to Benefit Startup Brewers, Winemakers and Distillers

For certain brewers, wine makers and distillers, the gift-giving season did not necessarily end in December. The Alcohol and Tobacco Tax and Trade Bureau (TTB) recently announced it has adopted changes that may impact the tax...more

The PFIC Regulations Get a Facelift

On December 28, 2016, the Treasury issued final regulations (T.D. 9806) that primarily address passive foreign investment company (PFIC) ownership and reporting rules and largely adopt 2013 proposed (REG-140974-11) and...more

New IRS Reporting Rule Could Bite Unwary Foreign Investors

There are two main sources of reporting requirements for foreign investors in the United States — the Internal Revenue Service and the Bureau of Economic Analysis. The IRS recently upped its game by requiring reports from...more

ITC Solicits Public Comments On MTB Petitions - 45-Day Comment Period Open Until February 24, 2017

The U.S. International Trade Commission (“ITC”) is now accepting public comments on Miscellaneous Tariff Bill (“MTB”) petitions for duty suspensions and reductions that timely were filed with the agency by December 12, 2016,...more

MoFo New York Tax Insights - Volume 8, Issue 1

The Top 10 New York Tax Highlights of 2016 - It’s the New Year, and before we begin afresh, we look back at this past year with our list of the Top 10 New York tax highlights of 2016. 1. The New York State Tax...more

Waking Up from a Long Winter’s Nap … the Border Adjustment Tax is the Sleeper Issue in the House Republican Tax Reform Blueprint

Thanks to the Republican sweep of the White House and the Congress, all the talk in recent years about tax reform is on the verge of turning into action. What many dismissed as idle chatter before Election Day suddenly...more

HMRC Publishes Guidance on the Tax Treatment of Clawback of Remuneration in the UK

Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...more

TTB Changes Under the Fall Edition of the Unified Agenda

On December 23rd, 2016 the federal government published its Fall edition of the “Unified Agenda” – a bi-annual compilation of all ongoing federal rulemaking projects. Attached is a copy of the TTB detail from this latest...more

Task Force Report: Taxation and Pricing of Cannabis

On June 30, 2016, the Minister of Justice and Attorney General of Canada, the Minister of Public Safety and Emergency Preparedness, and the Minister of Health announced the creation of a nine-member Task Force on Cannabis...more

Online Travel Company Did Not Owe Indiana Sales And Innkeeper’s Taxes For Facilitating Rental Of Hotel Rooms

In Orbitz LLC v. Indiana Department of State Revenue (Dec. 20, 206), the Indiana Tax Court characterized the key issue as “whether the Department erred in issuing sales and innkeeper’s tax assessments against Orbitz based on...more

Some Tax Law Changes That Take Effect in 2017

No new tax legislation has come forth yet, but per tax laws passed in prior years, some changes in the law will occur in 2017. Chief among them...more

Amendment Protocol to the India-Singapore Tax Treaty Inked

Capital gains on alienation of shares to be taxable by India. The India-Mauritius tax treaty was amended by way of a protocol signed by the two countries on May 10, 2016—marking a landmark shift in India’s taxation...more

2016 – A Bad Year For Bad Guys in Energy

Let’s look back at a cavalcade of crooks, criminals and miscreants who met up with justice in 2016. We do it to be reminded of the others who will be lurking in the 2017 shadows....more

Rollover Equity in the Sale of a Family-Owned Business

If you sell your family-owned business to a private equity buyer, the buyer will most likely pay a portion of the purchase price with equity in the buyer’s new company, rather than with cash. The equity that you receive in...more

India Amends Capital Gains Tax Treaty With Singapore

The Government of India amended its double taxation avoidance agreement (DTAA) with Singapore on December 30, 2016. The amendment allows the Government of India to levy source-based capital gains taxes on foreign direct...more

Applying the Look-Through Rules in Determining 'Investment Partnership' Status Under Section 721(b) - Tax Update Volume 2017,...

Careful Evaluation and Planning Should Be Undertaken When the Partnership Is Formed and When Assets Are Contributed to Evaluate the Potential Impact of Section 721(b). Many taxpayers choose partnership structures...more

The IRS's Stricter(?) Stance on Regulated Investment Company Investments in Commodities - Tax Update Volume 2017, Issue 1

While the IRS's Proposed Regulations Are Not Yet Effective, RICs Should Carefully Consider Whether Their Portfolios or Policies Run Afoul of the New Rules. In order for a corporation to qualify as a regulated investment...more

Tax Reform in the New Administration

The upcoming change in administration, combined with retained Republican control of both houses of Congress, is expected to result in significant changes in the federal income tax system, on both the domestic and...more

Who Is The Taxpayer?

Back to Basics - This is not a silly question. In fact, it is often one of the most difficult issues confronted by a tax adviser, and it arises from one of the most basic of tax principles; specifically, that income is...more

Estate Tax Impact of Life Insurance Required by Divorce

Please see chart below for more information....more

Financial Services Quarterly Report - Fourth Quarter 2016: UK Autumn Statement 2016: Tax-Related Impact for the Financial Services...

In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more

South Carolina Department of Revenue Issues Property Tax Guidance for Fiscal Year Manufacturers

The South Carolina Department of Revenue (the “Department” or “DOR”) issued SC Revenue Ruling #16-12 on December 16, 2016. The ruling provides guidance to manufacturers on property tax return filings, assessment procedures,...more

Financial Services Quarterly Report - Fourth Quarter 2016: The Impact of New U.S. Partnership Audit Rules on Investment...

The U.S. Bipartisan Budget Act of 2015 amended the provisions of the U.S. Internal Revenue Code of 1986, as amended (Code), governing partnership audit proceedings. The new provisions are designed to simplify the ability of...more

U.S. Antiboycott Compliance: New Federal List Published

Companies doing business in the Middle East take note: The Treasury Department recently published its quarterly list of countries that currently require participation or cooperation with an international boycott, such as the...more

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