Tax Finance & Banking

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Worldwide Exchange of Tax Information: OECD Expands upon FATCA to Add New Requirements

While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For...more

SB 628: Investing Tax Increment in Infrastructure and Economic Development

It will be slightly easier for municipalities and special districts to harness the tax increment for financing infrastructure projects under Senate Bill 628. Infrastructure Financing Districts, which have existed in...more

High Net Worth Family Tax Report, Vol. 9, No. 3

In This Issue: - Tax planning strategies to consider before the end of the year - The IRS announces inflation-adjusted amounts for 2015 - Case update: Taxpayer’s deduction for interest capitalized in loan...more

President Approves One-Year Extension of Charitable IRA Rollover

On December 19th, President Obama signed H.R. 5771, known as the “Tax Increase Prevention Act of 2014.” Among other things, this legislation extends the favorable charitable IRA rollover rule to gifts made in 2014. ...more

Currency Conversion Concerns: New York Issues Guidance on Virtual Currencies

On December 5, 2014, the New York Department of Taxation and Finance (Department) released TSB-M-14(5)C, (7)I, (17)S. This (relatively short) bulletin sets forth the treatment of convertible virtual currency for sales,...more

Member-Employees of Limited Liability Companies

Every now and then, the question arises: can an owner of a limited liability company (LLC) also be an employee of that company? The answer boils down to how the LLC elects to be taxed. ...more

Summary of the Tax Extenders in the Tax Increase Prevention Act

On Friday, December 19th, President Obama signed the Tax Increase Prevention Act (“TIPA”), H.R. 5771, into law. TIPA is commonly referred to as the “tax extenders” bill as it extends certain expiring provisions of the...more

Bank Leumi Enters Into DPA with U.S. Department of Justice

A major Israeli international bank admitted that it conspired to aid and assist U.S. taxpayers to prepare and present false tax returns to the Internal Revenue Service (IRS) by hiding income and assets in offshore bank...more

Congress Extends IRA Qualified Charitable Distribution Rule: Action During 2014 Is Required for Taxpayers Interested in Taking...

Individuals who act quickly can receive a tax break for distributions in 2014 from an Individual Retirement Account (IRA) to a qualified charity. For the past four years, a distribution of up to $100,000 from an IRA paid...more

Section 363 Sale Order Enjoining Successor Liability Claims Not Subject to Subsequent Attack by State Agencies

A recent decision in the ongoing bankruptcy proceedings for Chrysler has reinforced the authority of a bankruptcy court to interpret its own sale orders, and where appropriate, to enforce such an order by preventing creditors...more

IRS Examinations of Forms 1040 - What to be Mindful Of in 2015

Taxpayers and representatives need to be mindful that the IRS Appeals Office has implemented what is known as the Appeals Judicial and Culture (AJAC) Project....more

Congress Approves Tax Extension Bill

TWO WEEKS ONLY! SAVE NOW! Congress has finally approved the extenders bill in what is widely viewed as terrible tax policy, but a welcome holiday gift nonetheless. The Tax Increase Prevention Act of 2014 extended a...more

Senate Approves QCD Tax Extender and ABLE Accounts – President Approval Expected Shortly

In two earlier blog posts we mentioned that the House had passed one bill to extend a number of tax breaks and had passed another bill, the ABLE Act, which would provide added benefits to individuals with disabilities....more

Municipal Bond Interest Paid By a Bond Insurer After an Issuer’s Bankruptcy Discharge Can Remain Tax-Exempt

In the aftermath of recent municipal bankruptcies in which issuers proposed and/or implemented bankruptcy plans involving partial discharges of the issuer’s payment obligation on insured bonds, there has been increased focus...more

UK Targets Corporate Profits Of Multinational Enterprises With Sweeping Tax Changes

On December 3, the UK Government announced its intention to introduce a new “diverted profits tax” (DPT) to take effect on April 1, 2015. Draft legislation was published on December 10 and is now subject to a public...more

Pennsylvania Unwraps Final Market-Sourcing Guidance

The Pennsylvania Department of Revenue (the Department) recently finalized its Information Notice on sourcing of services for purposes of determining the appropriate net income and capital franchise tax apportionment factors....more

Corporate & Tax E-Note - December 2014

In this issue: - SEC Crowdfunding Rules Delayed Until October 2015 - Mega M&A Experiencing One of Biggest Booms in History - Some Small Business Owners Say Tax Break Extension Not Enough - 2014...more

Highlights of Final Regulations for Reporting of Specified Foreign Financial Assets

The Treasury Department has issued final regulations relating to reporting of specified foreign financial assets on Form 8938. The highlights include...more

IRA “Charitable Rollover” Retroactively Extended Through 2014

Background - As a part of the so-called “Cromnibus” bill, Congress has extended dozens of expired “temporary” tax breaks for 2014. Included in that group is a rule that allows for tax-free treatment of certain...more

IRA Charitable Rollover Extended

For some, the end of the calendar year means more than just the deadline for charitable contributions for the tax year. December 31 is also the deadline to take certain mandatory distributions from individual retirement...more

Compensation Issues – Revisited

We have completed another retirement plan audit season and have noticed a number of common errors occurring with compensation. I previously discussed these issues in my blog series “Compensation: The Missing Link – Part 1”...more

IRS Simplifies Tax Reporting for Individuals With Canadian Retirement Plans

Under Article XVIII(7) of the United States-Canada Tax Treaty, a U.S. citizen or resident may elect to defer U.S. income taxation on income accruing under a Canadian registered retirement savings plan (RRSP) or registered...more

Senate passes Tax Extender Package at 11th hour

The Senate passed the “Tax Increase Prevention Act of 2014? (H.R. 5771) on Tuesday night just before Congress adjourned for 2014. As Molly Bryson described in her December 5, 2014 post following the House’s passage of the...more

FCA Dismisses Lord Black’s Tax Appeal

Earlier this year, in Black v. HMQ (2014 TCC 12), Lord Conrad Black unsuccessfully argued in the Tax Court of Canada that, due to his U.K. residency status, he should not be subject to Canadian tax on certain income and...more

Were These The Extenders That We Were Waiting For?

The Senate on December 16 passed a tax bill that retroactively extends a package of fifty-five tax provisions through the end of 2014. In other words, by the time President Obama signs the new law, it will remain in effect...more

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