Corporate Taxes

News & Analysis as of

Australian Tax Alert: Investment Manager Regime (IMR) – Bill To Implement Element 3 Is Now Law

Tax and Superannuation Laws Amendment (2015 Measures No. 1) Bill 2015 (the Bill), containing the third element of the IMR, has been passed by the Australian Parliament and received Royal Assent on Thursday 25 June 2015. This...more

Tax Review - June 2015

In This Issue: - Compensation for Uncollectible Debts Deprives Taxpayers of Their Eligibility to Benefit from VAT Relief for Bad Debts - Polish Definition of The First Occupation Inconsistent with the VAT...more

Tax Newsletter - March/April 2015 (China & Hong Kong)

In This Issue: The People's Republic of China: - China Tightens Tax Control Over Cross-Border Intercompany Payments - China Provides Further EIT Incentives For Integrated Circuit Industry - Expansion of...more

Corporate E-Note - June 2015

In this Issue: - IRS Issues Guidance on Portability: The IRS recently issued final regulations that provide guidance on the federal estate and gift tax applicable exclusion amount, in general, as well as the...more

NC Legislative Update for June 2015 #4

This Week - This week at the General Assembly was relatively dull compared to the last few weeks. The House Finance Committee used two meetings, Tuesday and Thursday, to review and discuss the tax package portion of the...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. Legislature Plans Long Day - Early this past Wednesday morning, the Maine House and Senate...more

Master Limited Partnerships: Proposed Tax Regulations Scale Back Activities Giving Rise to Qualifying Income

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...more

Publicly Traded Partnership Proposed Regulations

Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more

European Commission Launches Action Plan to Review EU Corporate Tax Framework and Close Tax Loopholes

The European Commission’s Action Plan for Fair and Efficient Corporate Taxation in the EU sets out proposals aimed at making corporate taxation in the EU more transparent and efficient, by reforming a system which is seen as...more

24 Months Through the Crystal Ball: Emerging Trends in State and Local Taxation (Part II)

This is the second of two articles guiding taxpayers through the next 24 months of state taxation’s turbulent waters. In this article, we address three additional significant trends. Corporate Income Taxation: Heat and...more

Cassation instance supports tax authorities in Oriflame case

On June 11, 2015, Moscow District Arbitration Court handed down its ruling in the controversial Oriflame case. In the case, the tax authorities challenged the lawfulness of a Russian organization deducting VAT and expenses...more

New Tennessee Tax Laws

The state of Tennessee recently enacted the Revenue Modernization Act (the "Act"). According to the state, while the legislation does not introduce any new taxes, it should raise revenue and create an even playing field in...more

Connecticut Tax Developments 2015 - Tax Increases...Again

Four years after enacting the largest tax increase in Connecticut history, the Connecticut General Assembly has adopted a new $40.3 billion biennial state budget that contains $1.5 billion in tax and fee increases. Few...more

Fairmont: OCA Dismisses Crown’s Appeal in Rectification Case

The Ontario Court of Appeal has dismissed the Crown’s appeal in Fairmont Hotels Inc. v. A.G. (Canada) (2015 ONCA 441). In Fairmont (2014 ONSC 7302), the taxpayer was successful on an application for rectification of...more

Massachusetts Tax Developments - A Reed Smith Quarterly Update: June 2015

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look at the most recent developments in Massachusetts corporate tax, provide some administrative updates, and discuss some hot...more

MoFo New York Tax Insights - Volume 6, Issue 6 - June 2015

In This Issue: - Tribunal Reverses ALJ and Permits Combination Based on Unitary Business and Distortion - “Flat Sum Settlement” with IRS Held Not to Constitute Reportable Federal Change - Tribunal Holds NYS...more

Spotlight on Tennessee: 2015 Tax and Related Legislation

The 2015 Legislative Session, 109th General Assembly, considered a large number of tax and related initiatives. Many of these initiatives have been enacted, some with very far reaching impact upon the tax climate in this...more

Global Connection - June 2015

The latest edition of Global Connection offers insight into a potential money laundering crackdown in the real estate sector, information on the Federal Trade Commission’s approach to data breach investigations and a legal...more

House Judiciary Committee Approves Three State Tax Bills

Yesterday, on June 17, 2015, three state tax bills were favorably reported to the United States House of Representatives (House) by the House Judiciary Committee (House Judiciary) after considering each during a half-day...more

Kyiv Tax Newsletter (Ukrainian)

Cancellation of the Military Tax on Currency Exchange Transactions - On 12 May 2015 the Verkhovna Rada of Ukraine adopted the Law of Ukraine “On Amendments to the Tax Code of Ukraine in Respect of the Military Tax” which...more

Kyiv Tax Newsletter

Cancellation of the Military Tax on Currency Exchange Transactions - On 12 May 2015 the Verkhovna Rada of Ukraine adopted the Law of Ukraine “On Amendments to the Tax Code of Ukraine in Respect of the Military Tax” which...more

Appellate Tax Board Case Update: MassMutual Proves Intercompany Debt is True Debt

Today, the Appellate Tax Board (“ATB”) released its Findings of Fact and Report in the related cases of Massachusetts Mutual Life Insurance Company and MassMutual Holding LLC v. Commissioner and MML Investor Services, Inc. v....more

North Carolina General Assembly Week in Review

The Senate budget process continued this week, though at a slower pace than members had planned for in the schedule released last month. Budget votes originally scheduled for Wednesday and Thursday of this week were delayed...more

Outbound IP Transfer in an F Reorganization

In one corner, we have Code §368(a)(1)(F) which generally allows for a corporation to move from one jurisdiction to another without triggering gain or other immediate adverse income tax consequences. The purpose is to allow...more

Tax Amnesty Hits the Midwest (and Beyond)

With many state legislatures wrapping up session within the past month or so, there has been a flurry of last-minute tax amnesty legislation passed. Nearly a half-dozen states have authorized upcoming tax amnesty periods....more

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