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A Very Scary Time of the Year: MTC Joint Audit Selection

With both Halloween and the Multistate Tax Commission (MTC) Income Tax Audit selection nearing, taxpayers should prepare themselves for the possibility of being spooked in the near future. On Thursday, October 30, from 2-4...more

Tax Increment Financing and Tax Abatement Programs: The Part You Play

School districts in Ohio play a very important role in tax increment financing and tax abatement programs. At a minimum, school districts receive notice that a city, county, or township will be approving a property tax...more

Southeast State & Local Tax: Important Developments - September/October 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA - INDIVIDUAL INCOME TAX...more

Spotlight on Tennessee: Ruling Highlights Importance of State Income Tax Considerations for Section 338 Elections

In Spotlight on Tennessee: Letter Ruling Addresses Treatment of a Section 338(h)(10) Election, dated July 10, 2014, we examined how Tennessee treats the federal election under Internal Revenue Code Section 338(h)(10) for...more

Sale-leasebacks accommodate buyer and seller in today’s healthcare real estate market: 7 reasons why they work, 5 pitfalls to note

For many years, low interest rates allowed companies with strong credit ratings to obtain access to cheap capital through traditional financing methods – meaning there was little enthusiasm for sale-leaseback...more

Beneficial Owner Disclosure and Its Potential Impact on Global Financial Businesses

As part of the continued international focus on combatting cross-border tax evasion and other financial crimes, during the June 2013 Lough Erne Summit presided over by the United Kingdom (G8 Summit), the G8 countries agreed...more

California (Finally) Conforms to Federal Treatment of UBTI in Charitable Remainder Trusts

One of the most important tax attributes of charitable remainder trusts is that they are exempt from income tax – except, that is, when it comes to unrelated business taxable income (UBTI) of these trusts. For decades the...more

October 31 Amendment Deadline for Bank Holding Company Tax Allocation Agreements

On June 19, 2014, the federal banking agencies issued a final Addendum to their Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure which may require non-S corporation bank holding company...more

Patent Box or Mystery Box?

The Italian Government recently approved the “patent box”, a tax relief system for the incomes deriving from the exploitation of industrial property. This could be a good news. Around 6 months ago we campaigned for...more

Corporate tax exemption for U.S. investment funds investing in Poland Based on the ECJ C-190/12 case

On 10 April 2014, the European Court of Justice ("ECJ") issued a judgment in case C-190/12 concerning the authority of Poland to grant corporate income tax ("CIT") exemption to investment funds depending on where their...more

Enhanced Infrastructure Financing Districts: New Hope for Cities and Counties

On September 29, 2014, Governor Jerry Brown signed into law Senate Bill 628 (Chapter 785) which provides a mechanism for cities and counties to form Enhanced Infrastructure Financing Districts (EIFDs) to divert property tax...more

China State Council Approves Adjustment of Special Access Management Measures in Shanghai Pilot Free Trade Zone

Following the big change where registration was replaced by filing for establishment applications of companies excluded in the Negative List, China State Council further approves adjustment of the special access management...more

Luxembourg draft budget for 2015 submitted to Parliament

On 15 October 2014, the Luxembourg Minister of Finance submitted the draft budget for 2015 (the Budget Bill) to the Parliament. The Budget Bill does not overhaul the Luxembourg corporate tax environment, however, it proposes...more

Prorated Expenses, Finally Deductible

As of October 17, 2014, expenses incurred abroad on a prorated basis with parties that are not income tax payers in Mexico will be fully deductible to the extent certain requirements are met. The foregoing is pursuant to a...more

Tax Me Once

For technology and other start-ups, going public can be doubly taxing—literally. “Traditionally, a pre-IPO company is structured as a C corporation, which is legally subject to two tax layers, the first assessed on...more

Are Passive Foreign Investments Too Good to Be True?

“Invest in tax-free offshore funds!” Sounds great, right? Each year, many U.S. investors fall for these familiar sales pitches. Other investors are simply looking to diversify risk by investing in offshore...more

The Singapore-India Connection: A Robust Past and a Compelling Future

In determining the optimum gateway for investing into India, reliance on industry data may be the most prudent opening gambit. Data released by India's Department of Industrial Policy & Promotion peg Mauritius and Singapore...more

Tax Law Blog: IRS Revises Offshore Voluntary Compliance Programs

As of July 1, 2014, the Internal Revenue Service (IRS) has implemented several changes to the streamlined filing procedures for offshore compliance, as well as the Offshore Voluntary Disclosure Program (OVDP). These programs...more

Deadline Looming to Amend Your Tax Allocation Agreement

The October 31st deadline to review and revise your tax allocation agreement is rapidly approaching. Banks and their holding companies need to ensure their agreements are in compliance with new regulatory guidance that,...more

Changes to Thin Capitalisation and Non-Portfolio Dividend Exemption Rules

On 16 October 2014, changes to Australia's thin capitalisation and non-portfolio dividend exemption rules received Royal Assent. The changes to the thin capitalisation rules represent a significant tightening of the...more

New Scottish property transaction tax: Highest rate band for commercial property announced as 4.5%

John Swinney, the Scottish government's Finance Secretary, has announced the proposed rates and bands for the new Scottish property transaction tax known as the Land and Buildings Transaction Tax (LBTT). On 1 April...more

Tax Court Strikes Down “DAD” Loss Importation Tax Shelter

In consolidated cases known as Kenna Trading LLC, the Tax Court shut down an attempt to contribute foreign currency losses into a US partnership and syndicate the losses to investors by selling partnership interests followed...more

Outstanding Design Flaws in California’s Cap-and-Trade Program

On January 1, 2013, California embarked on a grand experiment with the launch of the world’s most complex cap-and-trade program. Under this program, companies operating in California, such as food processors, power producers...more

IRS Modifies Offshore Filing Procedures

The IRS has issued FAQs relating to the new streamlined procedures for offshore compliance, and for Delinquent International Information Return Submission Procedures....more

Bombay High Court Rules in Favour of Vodafone India in $490 Million Tax Dispute

On 10 October 2014, the Bombay High Court delivered a judgment in favour of Vodafone India Services Private Limited (Vodafone India) in a long-pending USD 490 million tax dispute. The Vodafone India intra-group transaction...more

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