Corporate Taxes

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Tax Newsletter - May/June 2014 (China & Hong Kong)

Editorial Note: Welcome to our redesigned Tax Newsletter. You will notice we have streamlined the publication and will now publish bi-monthly instead of quarterly. For major developments that may be highly...more

For Love or Charity – A Charitable Bailout Using Charitable Remainder Trusts for the Sale of a C Corporation

I have personally observed in my professional travels that many taxpayers are reluctant charitable donors. However, we you remind a business owner that they only have three choices when it comes to taxes (1) Pay yourself;...more

Time For a New Home?

The high number of companies, mostly U.S., eyeing acquisitions or ventures that will allow them to redomicile their business in the UK and Ireland is a major theme of this report. Mostly, it is about tax. But there is quite a...more

New judgment on tax treaty between Germany and the US

Hybrid US S-Corporation eligible for participation exemption. Refund practice of taxes withheld remains to be seen. In a recent judgment (file no. I R 48/12), the German Federal Fiscal Court has commented on Art. 1...more

Michigan Supreme Court Upholds the Compact Election

On July 14, 2014, the Michigan Supreme Court in a splintered 3-1-3 decision found in favor of IBM’s election to apply the Multistate Tax Compact’s three-factor apportionment formula to the now-repealed Michigan Business Tax...more

Spotlight on Tennessee: Letter Ruling Addresses Treatment of a Section 338(h)(10) Election

Tennessee does not expressly conform to most provisions in Subchapter C of the Internal Revenue Code. Instead, Tennessee's federal corporate income tax conformity is determined based on the "starting point" that Tennessee...more

Health Quest: Appeal allowed where Crown failed to properly plead assumptions

What is the result of the Crown’s failure to properly plead its assumptions in the Reply? This issue was considered by the Tax Court in Health Quest Inc. v. The Queen (2014 TCC 211) in which the Crown’s Reply included...more

Le novità introdotte dal Decreto Crescita: Minibond, concessione di finanziamenti e cartolarizzazione dei crediti

In data 24 giugno 2014, è stato pubblicato in Gazzetta Ufficiale n. 144, il decreto legge 24 giugno 2014 n. 91 (il "Decreto Crescita") che introduce: (i) misure a favore delle emissioni di obbligazioni...more

Doing Business in Canada: E-Commerce

E-COMMERCE - Canada has a vibrant Internet community. Because of the great expansion of the Internet in Canadian homes and businesses, Canada and its provinces have, in recent years, regulated Internet activity and...more

Japan To Reduce Corporate Income Tax Rate

The corporate income tax rate in Japan is known to be one of the highest worldwide. To encourage foreign companies to do business in Japan and make Japan a more attractive location for investments, Prime Minister Shinzo Abe...more

Supreme Court Provides Standard for Evidentiary Hearing in IRS Summons Enforcement Proceeding

On June 19, 2014, the Supreme Court unanimously ruled that taxpayers have a right to an evidentiary hearing in an IRS summons enforcement action when the taxpayer “offers some credible evidence supporting his charge” of...more

Court of Federal Claims: Merged Corporations are the Same Taxpayer for Interest Netting

In Wells Fargo, the Court of Federal Claims held that a taxpayer may net underpayment balances and overpayment balances among merged entities under Section 6621(d). Section 6621(d) provides that, to the extent the “same...more

Tax Reform Act of 2014: Potential Impact on Tax-Exempt Organizations

Many of the provisions in the proposed Tax Reform Act of 2014 (“TRA 2014”) released earlier this year would adversely impact tax-exempt organizations. For example, TRA 2014 would remove the long-time exclusion from unrelated...more

International Tax News - June 2014

NEW FOR SUPPLIERS OF DIGITAL CONTENT AND INTANGIBLES: DLA PIPER’S GLOBAL VAT GUIDE - Starting January 1, 2015, EU VAT rules for suppliers of digital content, telecommunications and broadcasting services are changing....more

Bolton Steel Tube: TCC Orders Crown to Reassessment in Accordance with Settlement

In Bolton Steel Tube Co. Ltd. v. The Queen (2014 TCC 94), the Tax Court of Canada allowed the taxpayer’s motion requesting an Order that would require the CRA to reassess the taxpayer in accordance with the terms of a...more

McKesson: Appellant’s Factum Filed

On January 10, 2014, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen (2013 TCC 404) (see Federal Court of Appeal File Nos. A-48-14 and A-49-14)....more

Sweden proposes new system for corporate taxation: a redistribution of tax payments in the business sector

A Swedish government committee mandated to analyze the Swedish corporate tax system - including the need for a more comprehensive approach to the overall deductibility of interest expenses, as well as the strengthening of the...more

Congress Turns Tax World Upside Down with New Focus on Corporate Inversions

Interest in corporate inversions has revived on Capitol Hill. Recent publicity surrounding pending deals has triggered comments and legislative proposals from tax writers and other members and stirred up the debate about...more

Michigan Enacts Changes To Administrative Tax Provisions Affecting Audits And Assessments

Michigan has enacted legislation that clarifies and streamlines a number of important tax administrative provisions. The changes affect the Department of Treasury’s ability to pursue and collect unpaid taxes from company...more

Kazakhstan Amends Legislation to Improve the Investment Climate

The amendments offer an incentives package for new projects in industries of prime importance. The Law on Amendments to Certain Legislative Acts of the Republic of Kazakhstan to Improve the Investment Climate (the Law)...more

Supreme Court Decides United States v. Clarke

On June 19, 2014, the United States Supreme Court held that a taxpayer has the right to examine Internal Revenue Service (IRS) officials regarding their reasons for issuing a summons only if the taxpayer points to facts or...more

Corporate Inversions Showing No Signs of Slowing Down

In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or...more

Tax measures included in the French Modified Finance Bill for 2014

The Modified Finance Bill for 2014 (the Bill) was presented to the French Parliament on June 11 2014 and will be reviewed by the Finance Committee of the lower Chamber of French Parliament (Assemblee Nationale) on June 18....more

Rhode Island 2015 FY Budget - CorporateTax Rate Reduced to 7% Effective 1/1/15: Corporate Rate will be the Lowest in the Region;...

Early this morning, the House adopted a budget that made significant changes to Rhode Island corporate income taxes. In order to make Rhode Island more competitive to attract and retain businesses, the corporate tax...more

New Simplified Conversion Process for Washington Corporations and Limited Liability Companies

Starting June 12, 2014, Washington law allows for the “conversion” of Washington corporations and limited liability entities into a variety of other business entities in Washington and other states through the simple adoption...more

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