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

Simple Advice to Retirement Plan Sponsors

by Ary Rosenbaum on

I don’t know about you, most of the advice I got growing up was usually wrong. Maybe some very unsuccessful people surrounded me when I was younger, but advice can be biased and self-serving at times. The best advice I would...more

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

German Constitutional Court Declares Parts of Provisions Regarding Forfeiture of Tax Losses and Loss Carry Forwards...

by Shearman & Sterling LLP on

The German Constitutional Court held in its decision dated 29 March 2017 (published on 12 May 2017) Section 8c sentence 1 German Corporate Income Tax Act (KStG) (introduced in 2008 and replaced by the identical provision of...more

Tax administrations prepare for automatic exchange of CbC reports - are you ready? Three takeaways

by DLA Piper on

OECD announced that another important step has been taken to implement country-by-country (CbC) reporting requirements, as signatories to the Multilateral Competent Authority Agreement on the Exchange of CbC Reports (the CbC...more

IRS Issues Guidance on “North-South” Transactions

by Proskauer - Tax Talks on

On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the “Ruling”), which helpfully clarifies that the separate steps of a typical “north-south” spinoff transaction will be respected, and announced...more

Viewpoints - Issue 28 - The Board’s Role in Overseeing Innovation

by King & Spalding on

Innovation has become an essential capability for any large public company if it wants to remain competitive. With some studies suggesting that 50% of the companies in the S&P 500 list could be replaced over the next 10...more

Succession Planning—Bet the Farm on It

by Ward and Smith, P.A. on

Despite recent trends toward consolidation in the agricultural industry, farming generally remains a family affair. According to the United States Department of Agriculture, 97 percent of all farms in the United States are...more

Corporate and Financial Weekly Digest - Volume XII, Issue 18

SEC/CORPORATE - US District Court Holds That Discretionary Tax Withholding is Exempt Under 16b-3 - Several companies have received shareholder letters seeking to recover short-swing profits from insiders under Section...more

It’s time for Profit Sharing Payment in Mexico!

As provided by the Mexican Federal Constitution and the Federal Labor Law (FLL), employees are entitled to receive profit participation on their employer’s profits every fiscal year. Ten percent of the company’s taxable...more

Small 401(k) Plans Have Bigger Problems Than Larger Plans

by Ary Rosenbaum on

Common sense would make you think that larger 401(k) plans would have the larger problems. Sometimes common sense and reality are mutually exclusive. Thanks to the quirks of the retirement plan business and how it prices...more

Development of court practice of determining the starting date for payment of property tax on a fixed asset that is ready for...

by Dentons on

On 28 April 2017 the Commercial Court of St. Petersburg and Leningrad Region rendered a decision in case No. ?56-87465/2016 (the “Decision”) under the claim of Penobeton-Pikalevo LLC (the “Company”). The case considered the...more

Commonwealth Court Unanimously Holds that Local Business Privilege Tax Must be Fairly Apportioned

by Cozen O'Connor on

A panel of the Commonwealth Court unanimously held that a local Business Privilege Tax (BPT) imposed on fees paid by Pennsylvania 7-Eleven franchisees to 7-Eleven’s regional office in the township was unconstitutional because...more

Tax Consequences to U.S. Shareholders of Holding Shares in a Passive Foreign Investment Company or PFIC

by Dorsey & Whitney LLP on

If a non-U.S. corporation (the “Company”) is a “passive foreign investment company” or “PFIC” for any tax year during which a U.S. shareholder owns shares in the Company, certain adverse U.S. federal income tax consequences...more

Development of court practice of determining direct capital investment for the purpose of applying the 5% withholding tax rate...

by Dentons on

On 3 May 2017 the Commercial Court of Chelyabinsk Region rendered a decision in case No. ?76-20508/2016 under the claim of Chelyabenergosbyt PJSC (the “Company”)....more

Recent Amendments to the Alberta Investor Tax Credit Program

by Dentons on

The Government of Alberta recently passed Order in Council 135/2017 (the Recent Amendments) which amends the Alberta Investor Tax Credits Regulation (the Regulations) and makes the Alberta Investor Tax Credit (AITC) program...more

Internal Revenue Service Announces It Will Recommence Issuing Private Letter Rulings on Certain Spin-Off Debt Exchanges

by Shearman & Sterling LLP on

The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation’s transfer of stock or securities of a controlled corporation (or “Spinco”) in...more

Energy Transfer, Williams, and the Circular Ownership of Stock

It is unheard of for a deal to die at the closing table because lawyers cannot deliver a required opinion regarding a transaction that they structured and negotiated. Yet, this is exactly what happened last year when two...more

What President Trump’s Executive Order Means for 501(c)(3) Political Activity

by Genova Burns LLC on

Recently, President Trump signed his Executive Order “Promoting Free Speech and Religious Liberty.” It directs the Secretary of the Treasury to exercise discretion to avoid taking any adverse action against an individual,...more

2017 Pennsylvania Tax Amnesty Program

Pennsylvania’s 2017 tax amnesty program (“Amnesty Program”) is currently underway. Through June 19, 2017, qualifying taxpayers who satisfy their delinquent tax liabilities will receive abatement of all penalties and one-half...more

Public Mergers and Acquisitions in Canada 2nd Edition - May 2017

by Bennett Jones LLP on

Canadian public merger and acquisition transactions in 2016 (in-bound and out-bound) comprised over C$400 billion in value with at least one-third of the transactions in Canada being fueled by foreign buyers. The second...more

Oil & Gas Tax Alert - "Trump's 15% Pass Through Tax Proposal: Say Goodbye to Joint Operating Agreements?"

by Porter Hedges LLP on

On Wednesday, April 26, President Trump submitted his tax reform proposal which is, for now, only about 100 words long. It contemplates a number of sweeping changes to the tax code. On the business side, these include a 15%...more

The Evolving Blueprint for Tax Reform: Candidate Trump vs. President Trump

by McNair Law Firm, P.A. on

On April 26, 2017, Treasury Secretary Steven Mnuchin and U.S. National Economic Council Director Gary Cohn, presented the blue print for President Trump’s tax reform proposal (referred to as the “2017 Tax Reform for Economic...more

Emmanuel Macron Elected President: French Taxation to Fall in Line with the European Average?

by Dechert LLP on

Following the election of Emmanuel Macron as President of the French Republic, you will find below a few examples of expected tax changes of potential importance to our clients....more

IRS Issues Guidance on "North-South" Transactions

On May 3, 2017, the IRS released Revenue Ruling 2017-9, which addresses two so-called "north-south" transactions in connection with spin-offs that are intended to be nontaxable under Section 355 of the Internal Revenue Code....more

Australian Federal Budget 2017 - 2018

by DLA Piper on

The Australian Government introduces a new major bank levy, increases the costs for foreign owners of Australian real estate and extends Managed Investment Trust concessions to investment in Affordable Housing from 1 July...more

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