News & Analysis as of

Capital Gains Income Taxes

Seattle’s New Income Tax May Affect Many More People Than Initially Thought, Including People Living Outside the City

by Stoel Rives LLP on

When Seattle passed its new income tax on July 10, many Washingtonians took note, but quickly moved on. The tax appeared to apply only to Seattle residents earning more than $250,000 for individuals or $500,000 for married...more

New Tax Court Decision Provides Planning Opportunities for Foreign Investors Investing in U.S. Partnerships

by Mintz Levin on

On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

by Shearman & Sterling LLP on

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...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

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

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

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

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

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

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

by Foodman CPAs & Advisors on

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

Lawyers: Give your clients a business entity checkup

by Thompson Coburn LLP on

As we prepare for perhaps another round of major tax law changes, you might want to consider the status of your clients’ legal postures. Making a client’s business structure more nimble or setting the stage to obtain outside...more

German Supreme Tax Court Confirms Capital Income Qualification Under Management Equity Programs – Close to a Breakthrough, But…

by Latham & Watkins LLP on

The German Supreme Tax Court has confirmed that a close to “market standard” Management Equity Program will be taxed on capital income principles. The decision (court number IX R 43/15) provides comfort with respect to most...more

Tax Reform in 2017? What is in Store for U.S. Businesses

by Snell & Wilmer on

With Republicans in control of the White House and Congress, one of the top priorities is tax reform. President Trump’s tax reform proposal and the House Republicans’ tax reform “Blueprint” suggest many changes to business...more

Capital gains not employment income for management participation returns

by Hogan Lovells on

On October 4, 2016 the German Federal Fiscal Court (Bundesfinanzhof) delivered its decision in respect of matter number IX R 43/15. The decision was not published until January 25, 2017 but was eagerly awaited by, in...more

Tax basis: The key to reducing gain on sale or deducting asset purchases

by Thompson Coburn LLP on

This article discusses key ideas used in reducing or eliminating gain subject to tax when you sell an interest in your business or when your business sells part or all its assets. These ideas can also possibly help those who...more

Change is Coming: A Look at Trump and Republican Tax Proposals

by Barley Snyder on

Tax reform is coming, and you better be ready. Regardless of how you voted in November, the United States will have a new president Friday and the Republican Party will be in control of both houses of Congress....more

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Becoming As Rich As Donald Trump: Financial and Tax Policies of the United States Government That Can Lead To Significant Wealth...

by M. Robinson & Company, P.C. on

Financial and tax policies of the United States government can help Americans achieve significant wealth through real estate ownership. These policies tend to favor taxpayers who, like the Trump family, are willing to commit...more

The Tax Treatment of New French Residents – A Bird’s Eye View

by McDermott Will & Emery on

Although France is a high tax country, it might be a suitable alternative for the UK residents who are contemplating taking up temporary residency in another jurisdiction. A number of tax breaks are indeed granted to the...more

Trump Administration's Tax Reform Likely

by Hodgson Russ LLP on

Donald J. Trump defied the polls and much of the national media to win the US presidential election on November 8, 2016. President-elect Trump will be sworn in and will take office as the 45th president of the United States...more

For high net worth individuals - What can you do before the end of the year to protect against potential changes in the tax laws? ...

by Dickinson Wright on

President-elect Trump has posted his tax proposals on his website. Although we are unable to say with certainty whether any of these proposals will be enacted, we address three of his proposals and our suggestions. Any of...more

Tax Truths: Volume 1, No. 2 – December 2016

by Ballard Spahr LLP on

AN ANALYSIS OF TAX LAW PROPOSALS OF THE PRESIDENT-ELECT AND THE HOUSE - President-elect Trump made tax reform a highlight of his campaign, calling for fewer tax brackets, lower individual rates, and reduced corporate tax...more

Estate Planning NOW: Preparing for a New Government

by Lewitt Hackman on

It’s impossible to predict what any future president will do, or what Congress will approve. But in light of comments president-elect Donald J. Trump made on the campaign trail, and given that Grand Old Party members will...more

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