Business Taxes

News & Analysis as of

UK Government Confirms Introduction of New Cap on Interest Deductibility

The UK Government has recently confirmed that it will be introducing a new cap on interest deductibility. Under the new rule, the ability of groups to obtain tax relief for interest will be limited by reference to a ratio of...more

Five Things about the IRS’s Proposed Regulations on the Spinoff Device and Active Business

On July 14, 2016, the Internal Revenue Service (IRS) proposed long-anticipated regulations tightening the “device” and “active trade or business” tests that are necessary for a corporation to distribute a subsidiary in a...more

South Carolina Economic Development Incentives: The Negotiated Fee in Lieu of Property Taxes

South Carolina has some of the highest business property taxes in the Southeast.  The state generally taxes land, buildings, machinery and equipment, and furniture and fixtures, but does not tax inventory, pollution control...more

Green Tax Incentive Compendium

Federal Tax Incentives for Renewable Energy and Energy Efficiency - A. GENERAL DESCRIPTION. The Federal Internal Revenue Code provides a business income tax credit in the amount of $0.023 (2015) per kilowatt hour of...more

South Carolina Property Tax Incentives: The Special Source Revenue Credit

While South Carolina has low income taxes, and comparatively low sales taxes as well, the state makes up for this by having some of the highest business property tax rates in the Southeast. These property taxes are generally...more

Throwout: New Jersey Supreme Court Denies Certification

The New Jersey Supreme Court has denied certification in Lorillard Licensing Company LLC v. Director, Division of Taxation, making the Appellate Division's decision final. The Appellate Division affirmed the Tax Court in its...more

Recreational Cannabis — Section 280E and Tax Efficient Structuring

I. The Conflict: The long arm of federal law Recreational cannabis businesses operate in a world of conflicting state and federal laws. Several states have legalized recreational cannabis, yet, under federal law, cannabis...more

My “Flippín” House?

Tax Strategies to Reduce Taxation and Build Wealth for House Flippers - Overview - I seem to be perpetually out to lunch. When I step on the scale too, this point is further confirmed. I do not know why I have...more

Rethinking Choice of Entity — Section 1202 Stock

We tax advisors spend plenty of time assessing whether a particular business is better suited operating as a flowthrough entity or as a tax-paying “C corporation.” Flow-through entities generally include sole...more

NJ Combined Reporting Update–Bill Continues Through Senate

Combined-reporting legislation continues to make its way through New Jersey’s Senate. Taxpayers should closely follow developments concerning this legislation to determine the impact on their companies. In January, we...more

Federal Tax Overpayment & Underpayment Interest Rates–3rd Quarter 2016

Please see Charts below for more information....more

Connecticut Tax Developments

2016 Legislative Session: The New Economic Reality - In his February 2016 State of the State address, Governor Malloy announced that his administration would be adopting a new approach to state budgeting in light of...more

New IRS Audit Rules: Is Your Healthcare LLC Ready?

The Bipartisan Budget Act of 2015 (the “BBA”), which was signed into law in November 2015, contains significant changes to the way the IRS will audit partnerships beginning in 2018. These changes will also have far ranging...more

The New Partnership Audit Regime Will Be Here Soon – Are You Ready?

On November 2, 2015, the Bipartisan Budget Act (“Act”) was signed into law by President Barack Obama. One of the many provisions of the Act significantly impacts: (i) the manner in which entities taxed as partnerships will be...more

South Carolina Textiles Communities Revitalization Act Enhanced

On May 23, 2016 the South Carolina Textiles Communities Revitalization Act was amended to remove a fifty percent cap applicable to the income tax credit provided by the Act. L. 2016, H5009. This taxpayer-friendly amendment...more

Changes Coming to the Long-Term Tax Exempt Rate Used in Calculating Section 382 Limitations - Tax Update Volume 2016, Issue 1

Changes to the formula for determining the long-term tax-exempt rate used in a section 382 limitation calculation after a company undergoes an ownership change may lower the amount of net operating losses the company can use...more

Make Sure the Corporation is in Good Standing Before Filing a Tax Court Petition

Many states will involuntarily or administratively dissolve a corporation for not paying or filing annual reports, fees, or tax returns. The ability of a dissolved corporation to engage in activities after dissolution depends...more

Legislation Revives and Permanently Extends 100% Gain Exclusion for Certain Sales of (C Corporation) Qualified Small Business...

For years now, conventional wisdom has been that, wherever possible, businesses should seek to operate as flow through entities (S corporations or partnerships) for income tax purposes. One rationale for this viewpoint has...more

Spotlight on Alabama: Department of Revenue Announces 2016 Tax Amnesty Program

The Alabama Department of Revenue (DOR) has announced the conditions, requirements and limitations of its tax delinquency amnesty program for 2016 (the Amnesty Program), pursuant to the Alabama Tax Delinquency Amnesty Act of...more

Proposed Section 385 Regulations May Dramatically Impact Portfolio Debt Planning

On April 4, 2016, the IRS and Treasury issued proposed regulations under Section 385 (the “Proposed Regulations“). The Proposed Regulations, which were thought to have been a response to post-inversion earnings stripping...more

NYC Extends Tax Credit Available to Biotech Companies

In late 2015, New York City Mayor Bill de Blasio signed into law a three-year extension of NYC’s biotechnology tax credit. The credit, which was set to expire on January 1, 2016, is now available through December 31, 2018....more

2016-17 New York State Budget

On April 13, 2016, Governor Andrew M. Cuomo signed the 2016-17 New York State Budget into law. We summarize the highlights of the revenue provisions below. Personal Income/Estate Taxes Personal Income Tax rates are scheduled...more

2015-16 New York State Budget

On April 13, 2016, Governor Andrew M. Cuomo signed the 2016-17 New York State Budget into law. We summarize the highlights of the revenue provisions below....more

Is it Debt or is it Not? Proposed Treasury Regulations Would Significantly Change Debt vs. Equity Analysis

Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the “Proposed Regulations”) under Section 385 of the Internal Revenue Code. The Proposed Regulations would significantly modify the tax...more

Renewable Alert Letter 25: Introduction of Listed Renewable Energy Funds

Procedures began in April 2016 for the long awaited listing of the first infrastructure fund on the Tokyo Stock Exchange targeted at investments in renewable energy plants and other infrastructure facilities. Among the...more

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