Business Taxes

News & Analysis as of

Proposed Sec. 367 Regs Say Goodbye to Goodwill Exception

Citing aggressive taxpayer positions, recently proposed regulations do away with the foreign goodwill exception to gain or income recognition for outbound transfers under Section 367. The rules also restrict the type of...more

IRS Audits of Partnerships: Big Changes are Coming

The Bipartisan Budget Act of 2015 (the “Act”), which was signed into law on November 2, will drastically change the way entities (including limited liability companies) treated as partnerships for U.S. federal income tax...more

Year-End Tax Planning and Expanded Scholarship Tax Credits

The Alabama Accountability Act of 2013 (the “Act”) provides state income tax credits to certain donors who make contributions to a state-approved scholarship granting organization (SGO) operating within Alabama. The Act was...more

New Hampshire Lowers Tax Rates, Creates Amnesty and Voluntary Disclosure Programs

After lengthy negotiations between legislators and Governor Maggie Hassan, New Hampshire enacted significant tax changes, including a cut to business tax rates, an increase in the research and development tax credit, and the...more

"Congress Overhauls Partnership Audit and Litigation Procedures"

On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more

Spotlight On Alabama: A Busy Tax Year in Review

It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more

The EC Challenge on Tax Rulings. Why it’s Important that Your Business Acts Now in Relation to EU Challenges to Tax Rulings

21 October 2015: Following state aid investigations, the European Commission has ordered Luxembourg and the Netherlands to recover unpaid taxes of €20-30m from each of Fiat and Starbucks. The Commission has confirmed that...more

Tax Evasion Vs. Tax Planning/Avoidance: Knowing The Difference Is Important

Last time, we began speaking about recent recommendations made by an international organization regarding tax avoidance which will reportedly make it harder for businesses to take advantage of tax law. As we noted, the...more

Law A' La Mode - Issue 17 October 2015

The Netherlands editorial team is delighted to bring you the 17th edition of Law a` la Mode, the quarterly legal magazine produced by DLA Piper’s Fashion, Retail and Design group for clients and contacts of the firm...more

Spotlight on Tennessee: Department of Revenue Proposes Tax Regulations

The Tennessee Department of Revenue (the Department) is in the process of proposing a wide range of regulations addressing current state tax laws. The purpose of this project is to promulgate new regulations to clarify and...more

Certain Michigan Taxpayers May Appeal Prior Assessments (Even for Repealed Taxes such as SBT, MBT)

In a Notice released recently by State Treasurer Nick Khouri, the Department of Treasury acknowledged that many taxpayers may have a right to appeal a prior tax assessment – even if many years have passed since that...more

Refunds for Improperly Collected Taxes Due to “Computer Glitch” Will Take Weeks: Michigan Dept. of Treasury

In testimony before the House Oversight and Ethics Committee yesterday Michigan Department of Treasury officials told lawmakers that refunds for taxes improperly collected on 76,000+ accounts due to a "computer glitch" would...more

Three-In-One Registration Reform

In order to accelerate the business registration reform and simplify the current registration procedures in China, the State Council issued the Opinions of the General Office of the State Council on Accelerating the...more

"Key Takeaways: Delaware LLCs - The Implications of Anson"

Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more

Disaster Preparedness and Your Taxes

If you live on the East Coast of the United States, you are probably following the weather forecast for Hurricane Joaquin very closely. If you are also filing your U.S. income taxes on extension and are trying to make the...more

UK tax treatment of US LLC: HMRC’s practice following Anson

We reported earlier this year on the UK Supreme Court’s decision in HMRC v Anson, in which it was held that a UK taxpayer, Mr. Anson, was entitled to claim relief against his UK tax liabilities for US tax paid on his share of...more

Joint Venture Governance And Business Opportunity Issues

The joint venture is a vehicle for the development of a business opportunity by two or more entities acting together, and will exist if the parties have: (1) a community of interest in the venture, (2) an agreement to share...more

MassTaxConnect: Massachusetts Business Taxpayers and Tax Professionals Await Rollout of New Secure Website on November 30, 2015

The Massachusetts Department of Revenue (“DOR”) released a training video about MassTaxConnect, the new secure website for tax administration in Massachusetts, on September 18, 2015. MassTaxConnect is scheduled for a rollout...more

Successful Strategies for Doing Business in Asia: Thailand (Updated)

WHAT ROLE WILL THE GOVERNMENT OF THAILAND PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Thai government regulates foreign direct investment by requiring foreign investors to obtain approval from the...more

Check Cashing, Tax Evasion, Structuring and Asset Forfeiture; The Making of a Bad Day

The following fact pattern should is representative of a tax evasion and structuring case. A taxpayer receives checks in the ordinary course of business from customers. Some of those checks are deposited into the business...more

Successful Strategies for Doing Business in Asia: Malaysia (Updated)

WHAT ROLE WILL THE GOVERNMENT OF MALAYSIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? Regulation of foreign investment in Malaysia is done both through legislation as well as governmental policies....more

Managing Tax Liabilities: Work An Experienced Legal Counsel

For businesses, managing tax liabilities is an important ongoing task and businesses often go to great lengths to situate themselves so as to minimize their tax obligations. One of the challenges in tax planning, though, is...more

Special Session Ends with Handful of Noteworthy Tax Bills, Predictions for Next Special Session

The first Special Session of 2015 ended on Tuesday, August 11, without accomplishing the primary objective of passing a General Fund budget for the 2015-2016 fiscal year. The Governor’s “call” for the special session included...more

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

International Tax Alert (US): Offshore e-Commerce Service Providers: Changes to Japan's Consumption Tax Act are Going into Effect

Offshore e-commerce service providers should make themselves aware of changes to Japanese law that affect their operations. Pursuant to a recent amendment of the Consumption Tax Act, a new Registration of Foreign...more

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