Corporate Taxes

News & Analysis as of

Potential roadmap to US tax reform: key points in the Hatch Report

As the work of the new Congress gets under way , there is general agreement that business tax reform is one of a handful of issues that may be achievable in the closing two years of the Obama Administration, and, in fact,...more

U.S. Supreme Court Update - February 2015

Court Considers Constitutionality of Maryland's Personal Income Tax - On 11/12/14, the U.S. Supreme Court heard oral arguments on the constitutionality of Maryland's personal income tax in Comptroller of the Treasury...more

U.S. Supreme Court Update - January 2015

Briefs Filed in Three State Tax Cases Set for Oral Argument - Merits briefs were filed in each of the three state tax cases on the Court's docket for the October 2014 Term. In Comptroller of the Treasury of Maryland v....more

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

In Private Letter Ruling 201432002 (the “PLR”), the IRS ruled that a foreign-to-foreign “F” reorganization did not implicate the Section 7874 anti-inversion rules. As a result, a foreign corporation (that was 100 percent...more

New Russian De-Offshoring Rules. The Impact On Foreign Investors And Russian Businesses

The debate over the strength of the de-offshoring initiatives between Russian Government hard-liners and representatives of the business community seems to have been finally resolved as the Russian lawmakers have adopted...more

Distressed Debt - UK Tax Changes

We discuss below changes to UK tax law in respect of corporate debt which take effect from the beginning of this year which will improve the UK tax position for distressed debt of a UK company....more

Rectification is About Intention – Not Interpretation

The Ontario Superior Court of Justice recently granted rectification in a case in which the CRA and the taxpayer differed in their interpretation and effect of a particular document. In Kaleidescape Canada Inc et al v...more

The Prospects for Corporate Tax Reform

The new 114th Congress has now convened and speculation is widespread as to whether tax reform can be successfully pursued in 2015. The successful 1986 Tax Reform Act navigated its way through a politically divided Congress a...more

ConocoPhillips: FCA Confirms Tax Court’s Jurisdiction to Determine Questions of Timing and the Validity of a Notice of Objection

In ConocoPhillips Canada Resources Corp. v. The Queen (2014 FCA 297), the Federal Court of Appeal overturned a Federal Court decision (2013 FC 1192) and dismissed an application for judicial review by the taxpayer finding...more

Illinois Industrial Insured Self-Procurement Tax Guidance Announced

As we have previously covered in detail, at the end of its 2014 regular legislative session, the Illinois General Assembly enacted a multimillion dollar tax on Illinois companies using captive insurance arrangements. The law...more

Luxembourg Tax Authorities Confirm Tax Treatment of Limited Partnerships

The Luxembourg tax authorities have confirmed, by means of the long-expected Circular Letter L.I.R. nº 14/4 (the “Circular”), the treatment of tax transparent Luxembourg limited partnerships in the form of a société en...more

Luxleaks - The next level

Until recently, the Luxemburg Government had resisted the European Commission's attempts to disclose the beneficiaries of tax rulings. It had even taken the information injunction to the EU Court of Justice. This has now...more

MoFo New York Tax Insights - Volume 6, Issue 1 - January 2015

In This Issue: - The Top 10 New York Tax Highlights of 2014 - Tribunal Affirms That a Charter Yacht Is Not Exempt from Use Tax as a Commercial Vessel - Court of Appeals Holds City Transfer Tax Does Not...more

Proposed Anti-Inversion Regulations Would Affect Foreign Insurers

For decades American companies have used so-called “corporate inversions” to lower their tax burdens on foreign-earned income. Typically, the American company is acquired by a foreign company located in a tax-favorable...more

PA Rev. Dept. Issues Guidance on Sales Factor Sourcing of Services

Shortly after issuance of our last newsletter in early December, the Pennsylvania Department of Revenue published Information Notice Corporation Taxes 2014-01, providing official guidance on the apportionment changes made by...more

TEFRA, Sometimes Forgotten But Not Gone

The Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”), as codified in Internal Revenue Code. § 6221, et seq., (“IRC”) is sometimes lost in the maze of more recent tax enactments. But, occasionally, it does rear its...more

IRS Private Letter Ruling Addressing Captive Professional Corporations Could Result in Significant “Consolidated” Tax Savings

On December 19, 2014, the Internal Revenue Service published PLR 201451009, favorably ruling that a for-profit management company could include its captive professional corporation as a member of its consolidated group for...more

Tax Extenders for the 2014 Tax Year: A Holiday Tax Gift from D.C.

Just days before the 2014 tax season draws to a close, new legislation was enacted in D.C. to provide a one-year retroactive extension for over 50 tax benefits and incentives which had expired in 2014. The one-year extension...more

Congress Passes Tax Increase Prevention Act of 2014 and Retroactively Extends Tax Relief Provisions

Welcome Tax Relief Provided to Individuals and Businesses Extended through Calendar Year 2014 - The Tax Increase Prevention Act of 2014 retroactively extends, through Dec. 31, various individual and business tax relief...more

It’s Your Burden: South Carolina Supreme Court Rejects Department of Revenue’s Application of Alternative Apportionment

The South Carolina Supreme Court issued its decision in CarMax Auto Superstores West Coast, Inc. v. S.C. Dep’t of Revenue, Opinion No. 27474 (S.C. Dec. 23, 2014), holding that the South Carolina Department of Revenue (the...more

Currency Conversion Concerns: New York Issues Guidance on Virtual Currencies

On December 5, 2014, the New York Department of Taxation and Finance (Department) released TSB-M-14(5)C, (7)I, (17)S. This (relatively short) bulletin sets forth the treatment of convertible virtual currency for sales,...more

Tax Extenders Passed by Congress

The President signed legislation passed by Congress which retroactively extends from January 1, 2014 many individual and business tax provisions which otherwise expired at the end of 2013. The extension is only for 2014, so...more

Summary of the Tax Extenders in the Tax Increase Prevention Act

On Friday, December 19th, President Obama signed the Tax Increase Prevention Act (“TIPA”), H.R. 5771, into law. TIPA is commonly referred to as the “tax extenders” bill as it extends certain expiring provisions of the...more

Congress Approves Tax Extension Bill

TWO WEEKS ONLY! SAVE NOW! Congress has finally approved the extenders bill in what is widely viewed as terrible tax policy, but a welcome holiday gift nonetheless. The Tax Increase Prevention Act of 2014 extended a...more

UK Targets Corporate Profits Of Multinational Enterprises With Sweeping Tax Changes

On December 3, the UK Government announced its intention to introduce a new “diverted profits tax” (DPT) to take effect on April 1, 2015. Draft legislation was published on December 10 and is now subject to a public...more

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