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Tax General Business

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

Carried Interest tax regime in Italy (art. 60 of Law 96/2017)

The new tax regime aims at discounting the taxation of the excess profit (i.e. profit in excess of the amount that the managers have contributed to the undertaking) attributed to investment managers or managers of target...more

Split Payment le nuove disposizioni contenute nella cd Manovrina 2017

L'art. 1 del D.L. 50/2017, convertito con Legge 96/2017 pubblicata in G.U. del 23 giugno 2017, ha introdotto nel Decreto IVA (DPR 633/1972) nuove disposizioni in materia di scissione dei pagamenti (di seguito anche "Split...more

Recent U.S. Tax Court Case Reverses Long Held IRS Position Regarding Taxation of Sales of Partnership Interests by Foreign...

by Locke Lord LLP on

Following the inauguration of the new administration in January 2017, many investors were anticipating the passage of a transformative tax reform bill at some point in 2017. Although legislative tax reform is seemingly...more

Expert witnesses in accounting disputes

by Allen & Overy LLP on

At a time of increasing disputes involving accounting evidence, this case debunks a number of assumptions about the approach taken by both HMRC and the First-tier Tribunal. HMRC do not always instruct their own employees as...more

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

1. What role does the government of Angola play in approving and regulating foreign direct investment? Foreign direct investment is a highly-regulated sector in Angola. In August 2015, the Angolan Government enacted Law...more

Big Tax Court Win for Foreign Investors in U.S. Partnerships

by Alston & Bird on

A foreign investor, not engaged in a U.S. trade or business, can sell stock in a U.S. corporation without fear of U.S. tax liability (with the notable exception of stock in certain U.S. corporations heavily invested in U.S....more

Texas Court of Appeals Confirms Power Generation Plants’ Eligibility for TCEQ Administered Tax Exemption

On July 11, the Texas Court of Appeals, Third District, at Austin, TX, decided the case of Freestone Power Generation, LLC, v. Texas Commission on Environmental Quality, et al., reversing the trial court’s ruling that eight...more

Reorganization Of Insolvent Corporations: Has A New Day Dawned? Nope

by Farrell Fritz, P.C. on

Withdrawal of Proposed Regulations- Earlier this year, the President directed the Secretary of the Treasury to review all “significant tax regulations” issued on or after January 1, 2016, and to take steps to alleviate the...more

Potential Risks From Pet Therapy Programs

by Fox Rothschild LLP on

Pet therapy programs have been expanding throughout the country, based largely on the increasing recognition that humans benefit from the human-animal bond. The human-animal bond is defined by the American Veterinary Medical...more

Partnerships Prepare For New Audit Regime

by Cole Schotz on

On November 2, 2015, new partnership audit rules, repealing existing TEFRA rules, were enacted in Section 1101 of the Bipartisan Budget Act (“BBA”). On August 15, 2016, Treasury published temporary regulations (TD 9780, 81...more

Did you know that Form 8938 filing obligations apply to Specified Domestic Entities?

by Foodman CPAs & Advisors on

A US Person that owns US entities like corporations or partnerships that conduct cross-border business may have a Form 8938 (Statement of Specified Foreign Financial Assets) filing obligation. IRS defines Specified...more

Renewal of U.S. FATCA Registration for Certain Investment Funds by Monday, July 31, 2017

Certain non-U.S. investment funds, including Bermuda funds, which qualify as foreign financial institutions (FFI), must enter into a legal agreement (“FFI agreement”) with the U.S. Internal Revenue Service (IRS) to be treated...more

New Partnership Audit Rules Apply Beginning January 1, 2018: Is Your Business Ready?

by K&L Gates LLP on

New partnership audit rules will be effective for audits of tax years beginning in 2018. Proposed Treasury Regulations have been released and are expected to be finalized in the next few months. (The comment period is open...more

Washington State Imposes New Reporting Requirements for Out-Of-State Sellers Not Collecting Sales Tax

by Stoel Rives LLP on

As part of Washington State’s efforts to collect more sales tax on out-of-state companies’ sales to Washington customers, the Legislature recently enacted H.B. 2163. The bill, signed by the Governor on July 7, imposes notice...more

IRS Issues Guidance To Examiners Handling BBA Partnership Audits

by Fox Rothschild LLP on

As many readers know, the Bipartisan Budget Act of 2015 (“BBA”) repeals the long standing TEFRA procedures governing IRS examinations of partnerships. As a result, beginning January 1, 2018, partnerships are subject to a...more

Pennsylvania Court Provides Commercial Property Owners With Defense to Tax Assessment Appeals

by Pepper Hamilton LLP on

On July 5, the Pennsylvania Supreme Court issued a unanimous decision confirming that all real estate in a taxing district is a single class (i.e., not subject to sub-classifications based on property type, such as...more

UK: The Biggest Shake Up of Employment Law in a Generation?

by Littler on

On July 11, 2017, the UK government published the Review of Modern Working Practices. The report was issued by Matthew Taylor, chief executive of the Royal Society of Arts and a former policy chief to Tony Blair. Current...more

Corporate Inversions

by Kelley Drye & Warren LLP on

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

Good News for Taxpayers: IRS Targets for Reform Burdensome Regulations on Partnerships, Corporations, REITs, Estates, and More

Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more

Cannabis Industry FAQ

by Pepper Hamilton LLP on

Can marijuana businesses receive federal copyright protection? Yes. The requirements for registration with the U.S. Copyright Office are that the work is original, creative and fixed in some form of expression. These...more

Massachusetts Revokes Directive Requiring Remote Sellers to Collect Sales Tax

by WilmerHale on

We previously reported to you that effective July 1, 2017, Massachusetts would require the collection of Massachusetts sales and use taxes by internet vendors that meet certain sales thresholds in Massachusetts pursuant to...more

Employee Loan Or Compensation?

by Farrell Fritz, P.C. on

Everyone recognizes the importance of debt financing to a business. The business needs liquidity to purchase or improve assets, or to pay expenses. It borrows the necessary funds from an institutional lender that requires...more

Alert: New Tax Court Decision Opens the Door for Tax Planning for Non-US Investors into US LLCs

by Cooley LLP on

On July 13, 2017, the US Tax Court issued a decision which may provide non-US investors more flexibility and potentially better tax outcomes with respect to structuring their investments into US LLCs and partnerships....more

UPDATE: Massachusetts Department of Revenue Revokes Directive Requiring Large Out-of-State Internet Vendors to Collect...

by Locke Lord LLP on

Our previous QuickStudy published on April 14, 2017, detailed Directive 17-1, issued by the Massachusetts Department of Revenue (“DOR”), which would have required all out-of-state internet vendors that in the prior taxable...more

Meals and Entertainment Expenses Can Be 100% Deductible

In general, a taxpayer may deduct only 50% of its business-related meals and entertainment expenses. This is commonly known as the 50% limit on meals and entertainment expenses. The 50% limit typically applies to the...more

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