Business Taxes

News & Analysis as of

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

Changes to IRS Partnership and LLC Audit Rules

Recent history has seen a proliferation of health care organizations—including tax-exempt organizations, for-profit companies, and physician practice groups—that have joined together to take advantage of different synergies...more

The Challenges of the Evolving Marijuana Industry: Reconciling State Legislation with Federal Prohibition

Cultivation, production, distribution, or possession of marijuana is a federal criminal offense under the Controlled Substances Act (the CSA). Yet, despite federal prohibition, state-sanctioned marijuana industries have...more

Proposed Change to North Carolina Excise Tax Law for Wine Shippers

Wine Shipper permittees may soon be able to file excise tax reports on an annual basis in North Carolina, rather than monthly. A proposed bill that would allow wine shippers to file excise tax reports annually is...more

Critical Tax Considerations When Structuring A Family Office

A wealthy family may create a family office to achieve a wide range of objectives. These objectives may include realizing the benefits of pooled capital in order to maximize the universe of available investment opportunities...more

Potential Refund Opportunity: Recent Michigan Business Tax Ruling Clarifies the Meaning of ‘Indirect’ Ownership

The Michigan Court of Appeals has held that Treasury cannot use the constructive ownership rules of IRC § 318 to determine whether a group of entities meets the threshold for mandatory combined reporting under the Business...more

The Hidden Tax Trap in Your Family Business—and How to Avoid It.

You have a business. You have a family. You have a family business. And frequently, the family makes decisions about the business. Sometimes, those decisions are not formalized....more

Partnership Audits of Private Equity Firms on the Rise

There has been buzz in the tax and private equity communities about the rise in audits of private equity firms by the Internal Revenue Service (“IRS”). This has been fueled by the restructuring of the IRS’ Large Business &...more

Global Private Equity Newsletter - Spring 2016 Edition: Recent Changes to Rules Governing Tax Audits of Partnerships

Congress recently amended the rules governing tax audits of partnerships that file U.S. partnership returns, including U.S. partnerships (and limited liability companies treated as partnerships) and certain non-U.S....more

California FTB to Discuss Apportionment of Combined Group Income

The California Franchise Tax Board (FTB) will hold a second Interested Parties Meeting at their office in Rancho Cordova on April 20, 2016, dealing with the apportionment of income for combined reporting groups with both...more

The IRS Releases CCA 201606027

On February 5, 2016, the Internal Revenue Service (IRS) released Chief Counsel Advice 201606027 (the 2016 CCA) in which the IRS concluded, among other things, that guarantees by a partner of a partnership’s liabilities that...more

Tax Treatment of “Bad Boy Guarantees” Challenged by Recent IRS Memorandum

I. OVERVIEW - A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that a so-called “bad boy guarantee” provided by a sponsor of...more

The Oregon Legislature Appears to Have Brought More Joy to the Cannabis Industry: House Bill 4014 Signed Into Law by Governor Kate...

As reported in my November 2015 blog post, in accordance with Internal Revenue Code (“Code”) Section 280E, taxpayers (for purposes of computing federal taxable income) are prohibited from deducting expenses related to the...more

The Taxation of the Marijuana Business (A Primer)

This blog post will be in two parts. The first part will provide the reader with an understanding of the laws and concepts associated with the taxation of the marijuana business. The second part will take these ideas and...more

City of Philadelphia’s BIRT: Is 3-Factor Apportionment Still an Option for Your 2015 Return?

Philadelphia’s business income and receipts tax—the so-called “BIRT”—is imposed at a whopping 6.41% rate.1 Add that to the state-level corporate net income tax of 9.99%, and the combined tax rate on corporate income subject...more

Pennsylvania Capital Stock Tax Phased Out; LLCs Now Are the Entity of Choice in PA; Procedure for Filing Final Returns

Until it expired at the end of 2015, Pennsylvania Capital Stock Franchise Tax (CSFT) was imposed on all limited liability companies (LLCs), corporations, joint-stock associations, and business trusts doing business in or...more

China Corporate Law Alert: Things You Need to Know about the “3-in-1 Certificate”

To simplify and unify business registrations and corporate filings, the Chinese government has initiated a reform to combine the business license, tax registration certificate and organization code certificate of a...more

Under the Dome: Inside the Maine State House

Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. Governor Paul LePage Delivers State of the State in Letter to Legislature - On Monday,...more

Massachusetts Department of Revenue Introduces Pilot Voluntary Disclosure Program

The Massachusetts Department of Revenue (the Department) released a draft administrative procedure introducing a pilot Voluntary Disclosure Program (the Program) for the settlement of uncertain tax issues for business...more

Pennsylvania Department of Revenue Releases Discussion Draft of Add-Back Notice

On February 2, 2016, the Pennsylvania Department of Revenue (the “Department”) released its first effort at providing public guidance regarding Pennsylvania’s intangible expense add-back provision. In its Discussion Draft of...more

eBook Doing Business in Massachusetts: A Guide to U.S. and Massachusetts Law for Non-U.S. Businesses

This guide is intended to provide foreign business-people with an introduction to the basic kinds of laws and regulations that affect the conduct of business in the United States, and particularly in The Commonwealth of...more

Not Enough Activity to Be a Developer

If you suffer a loss on the disposition of real property, you want to be treated as a developer for income tax purposes - that is, to be treated as engaged in a trade or business. That way, you can get ordinary loss treatment...more

NJ Senators Hold Press Conference on Combined Reporting

New Jersey Senators Lesniak (D), Greenstein (D), and Sarlo (D) held a press conference today concerning combined-reporting legislation that they are sponsoring....more

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