Business Income

News & Analysis as of

Sweeping Change to Partnership Tax Audit Procedures

A major change to partnership audits was signed into place by President Barack Obama on November 2nd following the passage of the Bipartisan Budget Act of 2015 by Congress on October 30th. Previously, partnerships with more...more

Allocation, Due Diligence, and More Record Keeping! New Draft Regulations on New York State’s Corporate Income Tax Allocation

2014 brought significant corporate income tax reform to New York State. This year, 2015, followed suit and brought many of those same corporate income tax reforms to New York City. To quote Donald Trump, these reforms are...more

Economic Presence Standard for Income Tax Nexus

In a question of first impression for Illinois, on May 12, 2015, Judge Schmidt of the Circuit Court of Sangamon County granted a summary judgment for the Illinois Department of Revenue, holding that the proper test for...more

Breaking News: California Supreme Court Hears Long-Awaited Gillette Oral Argument

On October 6, 2015, counsel for the taxpayer and the Franchise Tax Board (“FTB”) argued before the California Supreme Court in The Gillette Company & Subs. v. California Franchise Tax Board. This case has been watched closely...more

Domestic Partnership Agreements: Financial Disclosures and Privacy

To reduce risk of later attack on the domestic partnership agreement, domestic partners should make fair and reasonable financial disclosures to each other prior to signing the agreement. Each partner should disclose to the...more

Best in Law: IRS Moves Mean It's Time to Shift Family Entity Wealth

The IRS may take action very soon to eliminate or reduce a widely used and valuable family business entity wealth transfer strategy. The window of opportunity to take advantage of this strategy may close within the next month...more

IRS Issues Proposed Regulations Addressing Management Fee Waivers

Certain arrangements would be recharacterized as ordinary income, rather than as distributive shares of partnership income. On July 22, 2015, the US Treasury Department and the US Internal Revenue Service (IRS) released...more

Texas Floods: What You Need To Know About Your Insurance

Texas has recently suffered historic flooding, causing tremendous damage and destruction in areas affected by heavy rain and floodwaters. Because of the damage sustained, commercial policyholders may have significant...more

Recent Decision Finds No Business Income Coverage Where Flood Caused Order of Civil Authority

When Super Storm Sandy struck the Northeast on October 29, 2012, states, cities, municipalities and towns up and down the East Coast ordered hundreds of thousands of people to evacuate from their homes and businesses. ...more

Recent Decision Finds No Business Income Coverage Where Flood Caused Order of Civil Authority

When Super Storm Sandy struck the Northeast on October 29, 2012, states, cities, municipalities and towns up and down the East Coast ordered hundreds of thousands of people to evacuate from their homes and businesses. In the...more

Proving Your Business Income Loss: Defeating Insurance Company Challenges to Policyholder Evidence

Courts commonly observe that the purpose of Business Interruption or Business Income insurance is to put the policyholder in the same position it would have been in had there been no interruption. The Business Interruption...more

Indiana Department of Revenue Rules Forced Disposition is Nonbusiness Income

In Letter of Finding No. 02-20140306 (Dec. 31, 2014), the Indiana Department of Revenue (Department) determined that income from the sale of two operating divisions of a business pursuant to an order of the Federal Trade...more

The Oklahoma MLP Quarterly - 1Q 2014

The Oklahoma MLP Quarterly highlights changes in taxation, law and capital markets that affect master limited partnerships who have headquarters located in, or significant contacts with, Oklahoma. The publication is...more

Participation of 100 Hours May Be Sufficient to Generate Active Income Exempt from the 3.8 Percent Health Care Tax on Net...

As business owners begin filing their 2013 federal income tax returns and pay the 3.8 percent tax on net investment income for the first time, they should be aware that 100 hours of participation in an activity may be...more

Legal Alert: Court Holds Comcast Did Not Establish Unitary Relationship with QVC

Yesterday the Los Angeles Superior Court held that Comcast did not establish a unitary relationship with its 57% owned subsidiary, QVC. The court found for Comcast and held that the evidence presented at trial demonstrated...more

10 MLP Governance Facts

MLPs possess unique governance characteristics as compared to corporations.The number of master limited partnerships (MLPs) has grown significantly over the past five years, increasing from 59 in 2009 to over 100 in 2013. An...more

With 2013 Oregon Income Tax Changes, Some Businesses Should Revisit Their Ownership Structure

Oregon business owners operating in the form of sole proprietorships, wholly-owned LLCs, and closely held C corporations may wish to reconsider their business structure due to upcoming changes in Oregon tax law. As a result...more

Line Jumpers Individual Income Taxes

In This Presentation: - SC Rules – Resident Individual Income Tax - SC Rules – SC Nonresident Individual Income Tax - Assumptions - Additional Assumptions - Scenario 1 HQ is in North Carolina - SC...more

Unprecedented Flooding in Alberta, Canada: Insurance Coverage for Property Damage, Loss of Business Income and Extra Expenses

Three days of unusually heavy rainfall has caused extensive flooding in Alberta, Canada. Calgary, the epicenter of Canada’s energy industry, was particularly hard hit, with flooding of the city itself and widespread loss of...more

PA Tax Law News -- June 2013

In This Issue: Home Stretch to a PA Budget; PA to Project Vendor Overpayments In Some Audits; Township Business Privilege Tax Rejected; and Pennsylvania Supreme Court Upholds IFTA Liability. Excerpt from Home...more

Michigan Court Allows Multistate Tax Compact Election

On June 6, 2013, the Michigan Court of Claims became the second court in the country to hold that the Multistate Tax Compact (the Compact) is a binding multistate compact that cannot be repealed by a separate, subsequent...more

IRS Releases College And University Compliance Project Final Report – Implications For All Tax-Exempt Organizations

On April 25, 2013, the IRS released its College and University Compliance Project Final Report, which updates the interim report issued in 2010. ...more

State + Local Tax Insights -- Spring 2013

In This Issue: Factor Representation: Is It Unconstitutional for a State to Have It Both Ways?; Upcoming Speaking Engagements; Expanded California Sales and Use Tax Exclusions for Advanced Manufacturing Projects; and...more

IRS Releases Final Colleges and Universities Compliance Report: Reveals Significant Underreporting

A recent report of the IRS’ Exempt Organizations (EO) division provides the results of a multi-year audit of tax-exempt colleges and universities regarding their compliance with IRS reporting requirements. The report focuses...more

Compensation and Unrelated Business Income are Focus of IRS Colleges and Universities Report

Just a few weeks before many tax-exempt organizations file their annual Form 990, the IRS yesterday released its final report on the Colleges and Universities Compliance Project, which it had initiated in 2008 by sending...more

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