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Tax Updates

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

Owe Back Taxes? The IRS May Grant You Uncollectible Status

Sometimes seniors find themselves owing past-due federal taxes they cannot afford to pay. Although notices from the IRS can be especially frightening, there are solutions. ...more

AFRICA - A Legal Guide for Business Investment and Expansion: South Africa

1 .What role does the government of South Africa play in approving and regulating foreign direct investment? South Africa is a constitutional democracy and an active member of the international investment community. It...more

Growing Concerns with Proposed Amendments Affecting Private Businesses and their Shareholders

by Bennett Jones LLP on

On July 18, 2017, Minister of Finance Bill Morneau announced sweeping changes to the way private businesses and their shareholders are taxed. The Government's proposals encompass three broad areas: (1) income sprinkling...more

Are Trusts Still Useful If the Estate Tax Is Repealed?

With Republicans in control of Congress and the presidency, there is talk of eliminating the federal estate tax. In 2017 the tax affects only estates over $5.49 million, meaning that for more than 99 percent of Americans,...more

Unfiled Tax Returns: What Do You Do? (Part 2)

by McNair Law Firm, P.A. on

The United States has a voluntary income tax reporting system. U.S. citizens, permanent residents, and businesses here must annually file income tax returns with the IRS, reporting their “worldwide income”, deductions, and...more

FY 2018 Sequestration Reduction Percentage for Direct Pay Tax Credit Bonds Set at 6.6 Percent

by Bracewell LLP on

According to an update released by The IRS Office of Tax Exempt Bonds, the sequester reduction percentage applied to the payments made to issuers of direct pay bonds in fiscal year 2018 will be 6.6 percent. This percentage...more

Mistakes An Employer Should Avoid Starting A 401(k) Plan

by Ary Rosenbaum on

I’m a firm believer that you need to get off on the right foot if we start something new. Otherwise, you have tough time recovering. When I talk about getting off on the wrong foot, I always remember wanting to get involved...more

Assessing the Taxability of Solar Energy Systems in Michigan

by Varnum LLP on

The very practical concern of knowing how solar energy equipment is taxed in Michigan is just one of many questions for those considering such a project. Under Michigan's General Property Tax Act (the "Act"), real and...more

California Supreme Court Holds that Real Property Transfer Tax Can Apply to Transfers of Entities that Own California Real...

by Bryan Cave on

Under California law, there are two separate tax implications affecting California real estate transfers that result in a “change in ownership” of the real property - a property tax reassessment and a real property transfer...more

Luxembourg announces new IP tax regime

by DLA Piper on

Luxembourg has announced a new regime that offers a special tax incentive for certain income from intellectual property rights. The bill containing the new IP regime, which is expected to come into effect as of the 2018 tax...more

Federal Tax Liens In Foreclosure Proceedings

by Ward and Smith, P.A. on

Henkel v. Triangle Homes is a North Carolina Court of Appeals case with dueling tax foreclosure proceedings involving the same property. One foreclosure proceeding was for unpaid municipal taxes and the other for unpaid...more

Tanzania Overhauls Mining Laws, Fines Investor US$190 Billion: Is Your Investment Protected?

by Jones Day on

Recently, Tanzania enacted a series of mining laws that significantly erode protection for existing and future investments in the mining industry. As part of these measures, one foreign investor has been assessed a US$190...more

The Distinction Between Partnership Debt and Partnership Equity

by White & Case LLP on

Insights and strategies in a rapidly changing area for taxpayers who want to be characterized as partners for tax purposes but want an investment that economically is very close to debt. Much ink has been spilled on the...more

IRS Rejects Investors' Claim for Refined Coal Credits in Technical Advice

by King & Spalding on

In Technical Advice Memorandum 2017-29-020 (July 21, 2017) (the “TAM”), the IRS denied claims by two tax equity investors (the “Investors” or each an “Investor”) for renewable energy tax credits on grounds that the...more

Gain Realized By Non-Resident Foreign Partner Upon The Sale Of Its Interest In A U.S. Partnership Is Not U.S.-Source Income Unless...

by Roetzel & Andress on

In Grecian Magnesite Mining, Industrial & Shipping Co., SA, v. Commissioner of Internal Revenue (filed on July 13, 2017), the United States Tax Court overturned Revenue Ruling 91-32 (which had been relied on since 1991) and...more

Would You Take on a Job if the IRS Had Discretion to Decide Whether You Got Paid?

by Charles (Chuck) Rubin on

Raelinn Spiekhout was the personal representative of the estate of Deborah Scott. The estate was subject to claims of over $1.8 million dollars, including IRS claims for $591,406.05. The principal asset of the estate was real...more

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

1 .What role does the government of nigeria play in approving and regulating foreign direct investment? Due to the economic benefits that accompany Foreign Direct Investment (FDI), the Nigerian government strives to...more

Can Foreign Partners Now Exit Partnerships Tax Free?

by Bracewell LLP on

In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more

What’s New in Washington: 10 Things You Need to Know

The exuberance of a November election victory for Republicans has given way to the difficult reality of passing legislation in a closely divided Senate. While the GOP has made significant gains in the area of regulatory...more

China implements new tax and administrative measures to boost foreign investment

by DLA Piper on

The Standing Committee of the China State Council, in their meeting of 28 July, released a strong signal on the encouragement of foreign investment in China. The meeting resulted in several particular measures aiming to...more

Rehabilitation for residential use in Lisbon’17: supply and legal regimes for foreigners

by DLA Piper on

Portugal currently offers two attractive legal/tax regimes for foreigners who wish to buy a property in the country and live here. Get to know them. Tax regime for non-habitual residents - What is the Non-Habitual...more

Tips for Drafting Executive Employment Agreements – Tip #4 – Beware of 409A

by Bryan Cave on

This article continues with another tip for drafting executive employment agreements and the importance of consulting counsel. For every well drafted executive employment agreement in the business world, there seem to be...more

New Partnership Audit Regime Set to Take Effect in 2018, Proactive Planning Recommended

On November 2, 2015, Congress passed the new centralized partnership audit regime as part of the Bipartisan Budget Act of 2015 (BBA) which is set to take effect for the tax years beginning on or after January 1, 2018. The...more

MTC Offers 16 State Marketplace Seller Amnesty Initiative

by McDermott Will & Emery on

The Multistate Tax Commission (MTC) is moving quickly to implement a multistate amnesty program through its current National Nexus Program (NNP) for sellers making sales through marketplaces. The new MTC marketplace seller...more

Securitisation in Poland: Legal and tax aspects

by Hogan Lovells on

Securitisation transactions have been receiving increased attention as attractive alternatives for Polish companies, especially those who can derive large pools of receivables from the debtors which are consumers or...more

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