News & Analysis as of

Capital Gains

The Federal Government takes aim at private corporations and their shareholders

by Dentons on

On July 18, 2017, the Federal Government released a package of tax measures aimed to “improve fairness”, “close loopholes” and limit tax planning strategies that involve the use of private corporations. The suite of measures...more

Grecian Magnesite: Tax Court Finds Reliance on a US Tax Advisor Establishes Reasonable Cause

On July 13, 2017, the Tax Court, in Grecian Magnesite, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. 3 (2017), rejected Internal Revenue Service (IRS) arguments that, in order to establish good faith reliance, the...more

Tax Court Rejects IRS’ Position in Rev. Rul. 91-32

Grecian Magnesite Mining, a Greek corporation (GMM), owned an interest in Premier Chemicals LLC, a Delaware limited liability company classified as a partnership for US income tax purposes (Premier). Premier conducted a trade...more

Newsflash: Tax Court Reverses IRS Revenue Ruling

by Dechert LLP on

A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more

US Tax Court Exempts Gain on Sale of a Partnership Interest

by Latham & Watkins LLP on

Decision could open planning opportunities for non-US partners regarding sale of a partnership interest. The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more

Nate Smithson Provides an Update on Tax Reform

by Jackson Walker on

Jackson Walker partner Nate Smithson has prepared an updated guide to tax reform under the Trump administration. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax law. Please see...more

Update to Guide on U.S. Taxation of Nonresident Aliens

by Charles (Chuck) Rubin on

I first wrote a simplified guide to U.S. taxation of nonresident aliens before the Internet and emails. The first few editions were printed and mailed out to persons on our firm's mailing list. Eventually, I circulated it by...more

Sale Of A Contract: Capital Gain Or Ordinary Income?

by Farrell Fritz, P.C. on

Maximize Capital Gain- In the sale of a business, it is the goal of every business owner and his tax adviser to minimize the amount of gain realized and, to the extent gain is realized, to maximize the amount that is...more

Deferring Taxes but Keeping the Cash

by Slim Ventures LLC on

In recent years, many public and private companies have been able to defer capital gains tax on appreciated assets while keeping up to 95% of the proceeds (versus 65%-75% in paying taxes). ...more

Charitable Giving Strategies

by Bowditch & Dewey on

If you have been looking for ways to give back this summer, you might want to try something different. The majority of people donate to charitable organizations through gifts of cash, but this may not be the most...more

Nate Smithson Provides an Update on Tax Reform

by Jackson Walker on

Jackson Walker partner Nate Smithson has prepared an updated guide to tax reform under the Trump administration. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax law. Please see...more

Estate Planning Still Critical in Uncertain Times

by Bowditch & Dewey on

The “plan” unveiled by the Trump administration in late April to repeal the federal estate tax was a broadly vague outline of tax reform goals. The proposed changes did not mention the federal gift tax or generation skipping...more

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

Italy passes new rules for carried interest

by Hogan Lovells on

The Italian Government has at last put an end to the controversy around the characterisation of 'carried interest' for tax treatment purposes. By Law Decree no. 50 of 24 April 2017, which is to be brought into law by 23 June...more

The Evolving Blueprint for Tax Reform: Candidate Trump vs. President Trump

by McNair Law Firm, P.A. on

On April 26, 2017, Treasury Secretary Steven Mnuchin and U.S. National Economic Council Director Gary Cohn, presented the blue print for President Trump’s tax reform proposal (referred to as the “2017 Tax Reform for Economic...more

Australian Federal Budget 2017 - 2018

by DLA Piper on

The Australian Government introduces a new major bank levy, increases the costs for foreign owners of Australian real estate and extends Managed Investment Trust concessions to investment in Affordable Housing from 1 July...more

Waiver of contractual right

by Hogan Lovells on

In a binding private ruling published on 2 May 2017, SARS was requested to confirm the income tax, donations tax, capital gains tax and value-added tax consequences of the proposed waiver of a right to receive an annual...more

Nate Smithson Provides an Update on Tax Reform

by Jackson Walker on

Jackson Walker partner Nate Smithson has prepared an updated guide to tax reform under the Trump administration. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax law. Please see...more

Unexpected Risks of Early Exercise ISOs

by Dorsey & Whitney LLP on

Companies that permit the grant of early exercise incentive stock options (“ISOs”) do so primarily to limit the impact of the alternative minimum tax (“AMT”). However, due to fairly counterintuitive tax regulations,...more

Capital Gains Tax decision in SCA

by Hogan Lovells on

On 28 March 2017, a judgment was handed down by the Supreme Court of Appeal (SCA) regarding capital gains tax owed by a taxpayer on the proceeds of a sale agreement from 2007 that was cancelled more than three years later....more

When Financial Planning Meets Family Law

Late 2016, the Minnesota Supreme Court decided the case of Curtis v. Curtis (887 N.W.2d 249) and in so doing provided a lesson in how to invest $2,000,000.00 to maximize your return in an alimony case....more

Locke Lord Article: Tracking Tax Reform

by Locke Lord LLP on

With the recent release and subsequent quick defeat of the American Health Care Act (AHCA), healthcare reform dominated the news and tax reform was waiting for its turn in the spotlight. Tax reform was a major issue on the...more

2017 Federal Budget – Selected Tax Measures

On March 22, 2017 the Minister of Finance introduced Canada’s 2017 Federal Budget (2017 Budget). Despite persistent rumours, no change was proposed to the capital gains inclusion rate. The 2017 Budget does include a mix of...more

Auf Wiedersehen to the tax privilege on restructuring gains – a blow to the German restructuring tool kit

by White & Case LLP on

A recent judgment of the German Federal Fiscal Court (FFC) will have significant impact on the restructuring tool kit afforded under German law. The FFC has found that the existing practice of permitting a tax liability...more

Form Over Substance Sometimes Prevails in Tax Law – Estate of George H. Bartell et. al. v. Commissioner

by Garvey Schubert Barer on

In most areas of law, substance prevails over form. Code Section 1031 is possibly one of the few exceptions to this time-honored rule of jurisprudence. Under Code Section 1031, form may prevail over substance. The U.S. Tax...more

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