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AFRICA - A Legal Guide for Business Investment and Expansion: Egypt

1 .What role does the government of Egypt play in approving and regulating foreign direct investment? Egypt has traditionally been a leader in the Arab world in the political, cultural, and economic spheres. Due to recent...more

insights Newsletter - Summer 2017

Shumaker is pleased to present the Summer 2017 issue of insights. In it we discuss: - Proposition 65 Amendments Require Re-evaluation of Products and Warnings - Privacy Compliance Driven by the European...more

ALJ Forces Combination of Hedge Fund Group in New York City - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

On April 27, the New York City Tax Appeals Tribunal issued a decision requiring the related members of a hedge fund group to file a combined return for New York City tax purposes. However, the administrative law judge (ALJ)...more

U.S Tax Court Bounces Rev. Rul. 91-32: Sales of Partnership Interests by Foreign Partners May Not be Subject to U.S. Tax

by Dickinson Wright on

The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more

Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more

Maine Court Declines to Follow Textron; Work Product Rule Protects Tax Accrual Work Papers

by Pierce Atwood LLP on

In a well-reasoned decision, Maine Superior Court Justice Michaela Murphy refused to grant the State Tax Assessor’s motion to compel deposition testimony relating to the taxpayer’s tax accrual (FIN 48) work papers and related...more

Tax Planning for Investment Into the United States Through Hybrid Entities - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more

Carried Interest tax regime in Italy (art. 60 of Law 96/2017)

The new tax regime aims at discounting the taxation of the excess profit (i.e. profit in excess of the amount that the managers have contributed to the undertaking) attributed to investment managers or managers of target...more

Split Payment le nuove disposizioni contenute nella cd Manovrina 2017

L'art. 1 del D.L. 50/2017, convertito con Legge 96/2017 pubblicata in G.U. del 23 giugno 2017, ha introdotto nel Decreto IVA (DPR 633/1972) nuove disposizioni in materia di scissione dei pagamenti (di seguito anche "Split...more

Recent U.S. Tax Court Case Reverses Long Held IRS Position Regarding Taxation of Sales of Partnership Interests by Foreign...

by Locke Lord LLP on

Following the inauguration of the new administration in January 2017, many investors were anticipating the passage of a transformative tax reform bill at some point in 2017. Although legislative tax reform is seemingly...more

Expert witnesses in accounting disputes

by Allen & Overy LLP on

At a time of increasing disputes involving accounting evidence, this case debunks a number of assumptions about the approach taken by both HMRC and the First-tier Tribunal. HMRC do not always instruct their own employees as...more

AFRICA - A Legal Guide for Business Investment and Expansion: Angola

1. What role does the government of Angola play in approving and regulating foreign direct investment? Foreign direct investment is a highly-regulated sector in Angola. In August 2015, the Angolan Government enacted Law...more

Big Tax Court Win for Foreign Investors in U.S. Partnerships

by Alston & Bird on

A foreign investor, not engaged in a U.S. trade or business, can sell stock in a U.S. corporation without fear of U.S. tax liability (with the notable exception of stock in certain U.S. corporations heavily invested in U.S....more

Texas Court of Appeals Confirms Power Generation Plants’ Eligibility for TCEQ Administered Tax Exemption

On July 11, the Texas Court of Appeals, Third District, at Austin, TX, decided the case of Freestone Power Generation, LLC, v. Texas Commission on Environmental Quality, et al., reversing the trial court’s ruling that eight...more

Reorganization Of Insolvent Corporations: Has A New Day Dawned? Nope

by Farrell Fritz, P.C. on

Withdrawal of Proposed Regulations- Earlier this year, the President directed the Secretary of the Treasury to review all “significant tax regulations” issued on or after January 1, 2016, and to take steps to alleviate the...more

Potential Risks From Pet Therapy Programs

by Fox Rothschild LLP on

Pet therapy programs have been expanding throughout the country, based largely on the increasing recognition that humans benefit from the human-animal bond. The human-animal bond is defined by the American Veterinary Medical...more

Partnerships Prepare For New Audit Regime

by Cole Schotz on

On November 2, 2015, new partnership audit rules, repealing existing TEFRA rules, were enacted in Section 1101 of the Bipartisan Budget Act (“BBA”). On August 15, 2016, Treasury published temporary regulations (TD 9780, 81...more

Did you know that Form 8938 filing obligations apply to Specified Domestic Entities?

by Foodman CPAs & Advisors on

A US Person that owns US entities like corporations or partnerships that conduct cross-border business may have a Form 8938 (Statement of Specified Foreign Financial Assets) filing obligation. IRS defines Specified...more

Renewal of U.S. FATCA Registration for Certain Investment Funds by Monday, July 31, 2017

Certain non-U.S. investment funds, including Bermuda funds, which qualify as foreign financial institutions (FFI), must enter into a legal agreement (“FFI agreement”) with the U.S. Internal Revenue Service (IRS) to be treated...more

New Partnership Audit Rules Apply Beginning January 1, 2018: Is Your Business Ready?

by K&L Gates LLP on

New partnership audit rules will be effective for audits of tax years beginning in 2018. Proposed Treasury Regulations have been released and are expected to be finalized in the next few months. (The comment period is open...more

Washington State Imposes New Reporting Requirements for Out-Of-State Sellers Not Collecting Sales Tax

by Stoel Rives LLP on

As part of Washington State’s efforts to collect more sales tax on out-of-state companies’ sales to Washington customers, the Legislature recently enacted H.B. 2163. The bill, signed by the Governor on July 7, imposes notice...more

IRS Issues Guidance To Examiners Handling BBA Partnership Audits

by Fox Rothschild LLP on

As many readers know, the Bipartisan Budget Act of 2015 (“BBA”) repeals the long standing TEFRA procedures governing IRS examinations of partnerships. As a result, beginning January 1, 2018, partnerships are subject to a...more

Pennsylvania Court Provides Commercial Property Owners With Defense to Tax Assessment Appeals

by Pepper Hamilton LLP on

On July 5, the Pennsylvania Supreme Court issued a unanimous decision confirming that all real estate in a taxing district is a single class (i.e., not subject to sub-classifications based on property type, such as...more

UK: The Biggest Shake Up of Employment Law in a Generation?

by Littler on

On July 11, 2017, the UK government published the Review of Modern Working Practices. The report was issued by Matthew Taylor, chief executive of the Royal Society of Arts and a former policy chief to Tony Blair. Current...more

Corporate Inversions

by Kelley Drye & Warren LLP on

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

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