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Recent Revisions to Internal Revenue Code Affecting Alcohol Beverages

In December 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (PATH Act). The PATH Act amends several provisions of the Internal Revenue Code of 1986 (IRC) administered by the Alcohol...more

Virginia Trial Court Rules Against Taxpayer in Addback Case

In a case of first impression, the Richmond City Circuit has determined that Virginia’s “subject to tax” exception to intangible expense addback only applies to the portion of the royalty that the recipient included in its...more

Focus on Tax Controversy and Litigation - New Partnership Audit Procedures May Dramatically Affect the Assessment and Collection...

In addition to the discussion of the new partnership audit rules, this month’s issue features articles regarding a recent district court decision in Ellis v. United States regarding the attorney-client privilege and work...more

Supervisory “Concerns” with Shareholder Protection Arrangements

In December 2015 (following years of sporadic and seemingly random criticism) of shareholder protection arrangements, the Board of Governors of the Federal Reserve System issued guidance that the Federal Reserve “may” object...more

European Commission Publishes Anti Tax Avoidance Package

On 28 January 2016, the European Commission published a draft Anti Tax Avoidance Package in order to ensure increased tax transparency and effective taxation within, and outside of, the EU. The package includes a proposed...more

United States District Court Pushes Back Against Government in North Carolina Asset Forfeiture Case

In May of last year we highlighted the decision by the United States Attorney for the Eastern District of North Carolina to dismiss a forfeiture case he’d brought against Lyndon McLellan, the owner of a small convenience...more

Cross-Border Banking and Out-of-this-World Penalties - Dealing with the IRS when you have Foreign Bank Accounts

A United States citizen or resident that owns (or has signatory authority over) an account at a foreign bank with a value in excess of $10,000 annually must file a Report of Foreign Bank and Financial Account (or “FBAR”) with...more

The "New" New Jersey Uniform Trust Code: Creating Uniformity for Beneficiaries, Trustees and the Professionals that Advise Them

As an estate planning attorney, it is hard to contain my excitement that a version of the Uniform Trust Code (“NJUTC”) was enacted in New Jersey on January 19, 2016 with an effective date of July 17, 2016. With its passage,...more

Private Equity Fund Managers: Annual Compliance Reminders and New Developments

Summary of private equity firms’ compliance obligations, discussion of notable developments in 2015 and outlook for 2016. US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs),...more

Tax Advantages for Angel Investors

Angel investors should be excited about recent legislative changes that are likely to improve the overall after-tax returns on their investment portfolios. As a result of the Protecting Americans from Tax Hikes Act (PATH),...more

Wealth Management Update - February 2016

February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

New Rules for 831(b) Captive Insurance Companies

On December 18, 2015, Congress passed the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act), as part of a 2016 appropriations bill. The PATH Act includes significant changes to Internal Revenue Code section...more

Draft UK Income-based Carried Interest Legislation Published

Proposed new UK rules will tax carried interest in certain funds as income, with only specified funds entitled to capital gains treatment - The UK government published draft legislation on 9 December 2015 amending the...more

MoFo New York Tax Insights - Volume 7, Issue 2

State Tax Department Releases New Draft Article 9-A Combined Reporting Regulations - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise tax...more

Federal Appellate Court Rules that Certain Foreign Currency Options Are Subject to the Section 1256 Mark-to-Market Regime

Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options (and also, possibly, to foreign currency...more

European Commission Proposes an Anti-Tax Avoidance Directive

The proposed Council Directive marks another, significant, though likely problematic, step towards tackling tax avoidance across Member States. Background - The European Commission (the Commission) has been moving...more

Partnership Audit Regime Shakeup

The recent Bipartisan Budget Act of 2015 (the “Act”) sets forth a new tax audit regime for partnerships (and limited liability companies taxed as partnerships) that will have far-reaching consequences. The new audit...more

What is a Section 83(b) election and why is it helpful to entrepreneurs?

Start-up founders, executives and other employees should understand the role that Internal Revenue Code Section 83 plays in effective tax planning when certain equity incentive grants are given in exchange for services....more

FIRPTA reform under the Protecting Americans from Tax Hikes Act of 2015: key points for non-US investors

Among the reforms and provisions in the Protecting Americans From Tax Hikes Act of 2015 are several important changes to the Foreign Investment in Real Property Tax Act of 1980 (commonly referred to as FIRPTA) that are...more

BEPS Action 7: how the OECD's proposals to redefine a PE could affect multinationals

The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) Project aim to target aggressive tax planning strategies which have the effect of shifting profits from high tax jurisdictions to low tax jurisdictions....more

Estate Planning Pitfall - You haven’t taken state estate taxes into account

A generous gift and estate tax exemption means only a small percentage of families are subject to federal estate taxes. But it’s important to consider state estate taxes as well. Although many states tie their exemption...more

Pennsylvania Department of Revenue Releases Discussion Draft of Add-Back Notice

On February 2, 2016, the Pennsylvania Department of Revenue (the “Department”) released its first effort at providing public guidance regarding Pennsylvania’s intangible expense add-back provision. In its Discussion Draft of...more

Asset protection: Back to basics

Asset protection trusts can be highly effective vehicles for protecting wealth in today’s litigious society. But these trusts can be complex and expensive, so they’re not right for everyone. For those seeking simpler asset...more

MoFo Tax Talk - Volume 8, No. 4

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

Significant Changes to U.S. Taxation of REITs and Investments by Non-U.S. Investors in Real Property under the PATH Act

On December 18, 2015, President Obama signed into law an omnibus appropriations bill which included the Protecting Americans from Tax Hikes Act of 2015 (the "Act"). In addition to extending or making permanent a number of...more

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