Corporate Taxes

News & Analysis as of

New Tax Amnesty Opportunity for Indiana Business Taxpayers

On May 7, 2015, Indiana Governor Mike Pence signed into law P.L. 213, which establishes a tax amnesty program that might give business taxpayers with concerns about Indiana tax reporting a great opportunity to settle any...more

Diverted Profits Tax: counterbalancing the UK's "open for business" agenda?

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of...more

Guide To Doing Business in Australia: Taxation (Updated)

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed...more

Tax-Exempt Parent Companies with For-Profit Subsidiaries

Recently, tax-exempt organizations have inquired whether it was legally permissible to establish a for-profit subsidiary to perform profitable work developed by the non-profit parent. ...more

Plain and Simple: Maryland Tax Court Holds Insurance Company is Exempt from Corporate Income Taxes

Although taxpayers often complain that complying with the tax laws imposed by the numerous state and local taxing jurisdictions that exist in the United States is a burdensome process, many of these tax statutes also provide...more

IRS Chief Counsel Memorandum Clarifies that Correction of Section 409A Failures in Year of Vesting Will Not Shield Income...

Earlier this month, the Office of Chief Counsel of the Internal Revenue Service released a Memorandum clarifying the impact of a correction of a Code Section 409A operational failure before the date of vesting of nonqualified...more

Business Tax Reform High Priority

Last week, I was at the ABA Tax Section meeting in DC, and one refrain that I heard over and over is that tax reform is a major priority for Congress. The Obama administration has basically shut down the possibility of...more

Tax Policy Update

NUMBER OF THE WEEK: 15. The number of minutes it should take most Americans to do their taxes, according to potential GOP presidential candidate Chris Christie in a Wall Street Journal op-ed published last night. ...more

BVI and Cayman removed from Italy’s tax blacklist

On 1 April 2015 the British Virgin Islands (BVI), Cayman Islands and 19 other jurisdictions were removed from Italy’s blacklist of jurisdictions. As a result it will now be easier for Italian individuals and companies to...more

Midyear Tax Planning

As we approach the middle of the year, this is the perfect time to consider tax planning for your business and whether you need to make any changes to your current tax strategies....more

Triple Drop and Check

Sounds like an ice hockey term, but this is a tax blog so don’t get your hopes up. Parent corporation owns all the stock of subsidiary 1, which owns all the stock of subsidiary 2, which owns all the stock of subsidiary...more

Abu Dhabi is 30 Per Cent More Attractive - Film Commission offers unique rebate to international production companies

The UAE is constantly seeking new and innovative ways to encourage business growth across the Emirates. Film and TV production is one of the diverse range of areas in which the Emirate of Abu Dhabi has actively looked to...more

New IRS Rulings Should Provide Greater Certainty for Corporate Restructurings

On May 5, 2015, the Internal Revenue Service (IRS) issued two long-awaited rulings, Rev. Rul. 2015-09 and Rev. Rul. 2015-10, that should ease the lives of corporate tax planners. Each ruling addressed an increasingly common...more

IRS Rulings Clarify Tax Treatment of Multi-Tier Restructuring Transactions

By declaring a controversial ruling obsolete, the IRS removes uncertainty surrounding the tax effects of certain corporate restructuring techniques. A pair of revenue rulings the US Internal Revenue Service (IRS)...more

MoFo Tax Talk Volume 8, Issue 1

In This Issue: - IRS Rules Debentures Are Part of Straddle; Interest Non-Deductible - Stock Abandonment Produces Ordinary Loss - Tax Consequences of Negative Interest Rates - Renewed Discussion of a...more

One Dollar of Tax Would Have Avoided $94,671.53 of Penalty

A corporation filed a 2008 income tax return reflecting a tax liability of “$0.00.” In the following year, the Corporation made no estimated income tax payments, based on Internal Revenue Code Section 6655(d)(1)(B) which...more

Alas, the MTC Executive Committee Approves Its Transfer Pricing Program Design

After nearly a year of planning, the Multistate Tax Commission Executive Committee today approved the Arm’s-Length Adjustment Services Advisory Group (the Group) Final Program Design. The following six states have agreed to...more

$400 Million Surplus Could Trigger Corporate Tax Rate Reduction

North Carolina state officials have announced a projected $400 million revenue surplus for the current fiscal year. The anticipated surplus is mainly due to higher income tax payments and lower refunds compared to last year....more

Tax Policy Update

NUMBER OF THE WEEK: 1,462. The total number of comments received by the Senate Finance Committee’s five bipartisan tax reform working groups in response to the committee’s request for public input on overhauling the nation’s...more

Reporting Audit Changes – New York City Amends Provision on Apportionment

On April 13, 2015, Governor Andrew Cuomo signed into law two bills related to the 2015-2016 budget (S2009-B/A3009-B and S4610-A/A6721-A) (Budget Bill), containing several significant “technical corrections” to the New York...more

[Event] Breakfast With Your Finance & Bankruptcy Lawyers: The Risks and Rewards of Financings in Europe - May 13, New York, NY

This breakfast session is jointly presented by Sheppard Mullin and Bird & Bird LLP, and will look at the key issues to consider when structuring financings involving European counterparties and examine whether there are real...more

Corporate E-Note - April 2015

In This Issue: - State Regulatory Boards Are Open to Antitrust Liability, Says the Supreme Court - USPTO Issues Patent Eligibility Guidelines…So Now What? - Bond Financing: The Best-Kept Secret For...more

Tax Newsletter - January/February 2015 (China & Hong Kong)

In This Issue: To People’s Republic of China: -Draft Foreign Investment Law -New Developments On Indirect Transfers Of Properties By Foreign Investors -Exposure Draft Of Revised Tax Collection And Administration...more

Louisiana Court Rejects Imposition Of Franchise Tax Based On Ownership Of Partnership Interest

The Louisiana Court of Appeal reversed and remanded Bridges v. Polychim USA, Inc., No. 581,759 (La. Jud. Dist. Ct. Jan. 2, 2014) (unpublished), a case in which the trial court held that an out-of-state corporation was subject...more

New York City Legislation Enacts General Corporation Tax Reform

On April 13, 2015, Governor Andrew Cuomo signed New York’s 2015-2016 budget legislation, which, among other changes, conforms the New York City general corporation tax (GCT) to the most significant changes from last year’s...more

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