Income Taxes

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
News & Analysis as of

IRS Internal Memorandum Advises That Self-Employment Tax Applies to Profits From an Investment Manager

On September 5, 2014, the Office of Chief Counsel, Internal Revenue Service (IRS) released an internal generic legal advice memorandum advising an IRS field agent that the statutorily provided “limited partner” exception to...more

Inbound Acquisitions At A Glance - Update 2014

We are delighted to provide you the third edition of our “Inbound acquisitions at a glance” brochure. In today’s increasingly complex business environment, awareness of the tax environment in relevant jurisdictions is...more

To Caesar, Only What Is Due - An Opportunity under § 505(a)(2)(C) for Ad Valorem Taxes?

Plagued with financial uncertainty and inadequate resources, debtors often fail to take the steps that are needed to minimize property taxes in the period leading up to bankruptcy. Tax protests go unfiled and valuations go...more

It Wasn’t Wirth It: Nonresident Limited Partners Liable for Personal Income Tax on Discharge of Nonrecourse Debt

In June 17, 2014, in Wirth v. Commonwealth, 82-85 MAP 2012, the Pennsylvania Supreme Court (the “Court”) affirmed the Commonwealth Court’s holding that nonresident limited partners were liable for Pennsylvania Personal Income...more

State Revenue Departments Misapplying Federal Tax Law

State income tax laws generally build on federal tax law. The typical pattern is to begin the calculation of state taxable income with federal taxable income and then to modify it by adding or subtracting items where state...more

Streamline Procedure-What does non-willful mean?

In order to use the Streamline Procedures (domestic and non-resident) a U.S. taxpayer must certify that their failure to file a timely FBAR was non-willful. The term non-willful is essentially a “clinical” conclusion based...more

Hospital's Lab Testing for Non-Patients Held to be Related Activity

On July 11, 2014, the IRS released a Technical Advice Memorandum ("TAM") finding that a tax-exempt hospital's income from the performance of laboratory services for non-patients was not subject to the unrelated business...more

Editorial: Qualifying for Treaty Benefits Under the “Derivative Benefits” Article

Foreign persons are subject to U.S. federal income tax on a limited basis. Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on...more

FATCA: Trapped by the Land of the Free?

The Foreign Account Tax Compliance Act (FATCA) has been billed as the U.S.’s bold effort to go after tax dodgers and cheats. The picture painted is that of greedy rich people secreting their fortunes in offshore accounts and...more

MTC’s Market-Based Sourcing Recommendations for UDITPA: Too Little, Too Late?

Member states of the Multistate Tax Commission (MTC) voted to adopt proposed amendments to Article IV of the Multistate Tax Compact during their annual meeting in late July. The proposed amendments likely to have the most...more

Corporate Tax Inversions: Will Either Congress Or The Administration Act In 2014?

There may be significant legislative and regulatory activity over the next few months as the US Congress and the Obama Administration continue to grapple with corporate tax inversions. While it remains unlikely that...more

The ERISA Litigation Newsletter

Editor's Overview - This month's newsletter focuses on repayment of pension plan overpayments. Our issue discusses pension plan overpayments to participants, a plan administrator's duties to seek repayment, corrections...more

IRS Applies 20th Century Analysis To 21st Century Social Organization

Code §501(c)(7) provides an exemption from federal income tax for clubs organized substantially for pleasure, recreation, and other nonprofitable purposes if no part its net earnings inures to the benefit of a private...more

Does Filing for Bankruptcy Really Give You Tax Relief?

When times get desperate and tax liabilities pile up – filing for bankruptcy is an option many people consider. Taxes are “dischargable” in bankruptcy, but there are important rules you need to know....more

Time Limitations On Receiving Late Proof Of Foreign Status For Portfolio Interest Exemption Payments

Code Section 871(h) provides non-U.S. persons with a valuable exemption from U.S. income taxes on interest paid on registered U.S. obligations, commonly referred to as the portfolio interest exemption. Before a payor is...more

The Global Crackdown on Profit Shifting

CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your...more

McKesson: Respondent’s Factum Filed

Earlier this year, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen (2013 TCC 404) (see Federal Court of Appeal File Nos. A-48-14 and A-49-14). At...more

No UK corporation tax deduction for penalty imposed under the code of the Fédération Internationale de l'Automobile ("FIA")

In an appeal by HMRC against a decision of the First-tier Tribunal ("FTT"), the Upper Tribunal (Tax and Chancery Chamber) ("UT") decided that a penalty imposed on McLaren Racing Limited ("McLaren") in respect of a breach of...more

American Pleads Guilty to Hiding Money in Swiss Bank, Moving Money to Israeli Bank after UBS Scandal

On August 19, 2014, Bernard Kramer pleaded guilty in the Southern District of New York to conspiracy to defraud the United States and filing a false income tax return relating to his concealment of “at least $1.1 million” in...more

First Circuit Liberalizes Tax Deductibility Standard of False Claims Act Settlements

Appellate court affirms $50 million tax refund to FCA defendant, holding that the “economic realities” of settlement payments determine whether they are compensatory. Civil False Claims Act (FCA) settlements, which...more

Tax Reminders? Now There’s an App For That

We have previously blogged about litigation apps and the absence of Canadian litigation and tax litigation apps. Yesterday, the Canada Revenue Agency introduced a new tool for tax compliance with the release of the...more

How Windstream Ruling Will Affect Foreign Taxpayers

In general, a REIT is a special purpose entity for U.S. federal income tax purposes that requires at least 75 percent of the value of the entity’s gross assets to consist of real estate assets, cash, cash items, and...more

FATCA Alert: IRS Issues Final Version of the Form W-8BEN-E and Accompanying Instructions

On June 25, 2014, the IRS finally issued the instructions to the new version of Form W-8BEN-E, an 8-page withholding certificate to be completed by foreign entities. Previously, foreign individuals and most foreign entities...more

IRS Ruling Creates Opportunities for Tax Savings by Companies With Substantial Real Estate Assets

On July 29, Windstream announced that it plans to spin off certain telecommunications network assets into an independent, publicly traded real estate investment trust (REIT). Windstream made the announcement after it obtained...more

First Circuit Rules in Favor of Dialysis Operator in Tax Dispute

On August 13, 2014, the United States Court of Appeals for the First Circuit affirmed a district court’s judgment in a tax dispute proceeding that Fresenius Medical Care Holdings, Inc. (Fresenius) was entitled to more than...more

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