Corporate Taxes

News & Analysis as of

New York Budget Legislation

On March 31, 2014, New York State Governor Andrew Cuomo signed into law the 2014-2015 New York State Budget (Budget), which results in the most significant overhaul of New York’s franchise tax in decades. The Budget brings...more

New Guidance From IRS On At-Risk Rules For LLC Member Guarantees

The IRS recently released a chief counsel memorandum AM2014-003 on LLC Member Guarantees of LLC Debt and “Qualified Nonrecourse Financing.” These memorandums are very helpful because they provide the IRS’ interpretation of...more

Stay Ahead Of The Curve When Choosing Desired Tax Treatment

A foreigner starting business in the U.S. usually hires attorneys for visas, leases and licenses. The tax advisor comes later, when returns loom. This tendency is unfortunate because entering the U.S. starts the clock for...more

Taxation Of Copyright Sales: Ordinary Income Or Capital Gain?

Tax day presents several interesting questions for copyright holders, not the least of which is how the Internal Revenue Service (IRS) will treat income from the sale or exclusive license of a copyright. If a copyright is a...more

‘S Wonderful, ‘S Marvelous, ‘S Unreasonable

One of the reasons to choose an S-Corp instead of an LLC is tax savings. An S-corp does not pay any taxes at the corporate level, but instead all income is passed through to the shareholders, who are responsible for a number...more

IC-DISCS- Exporting the American Dream and Capitalism for Love of Country and Tax Benefits

I always loved the old Coca Cola commercial sung to the catch jingle “It’s a Small World” demonstrating the appeal of Coca Cola to all people around the globe. I think the same can be said about the idea of having to pay a...more

The First Dish is Served: Chairman Camp Unveils Comprehensive Tax Reform Discussion Draft

On February 26, 2014, House Ways and Means Committee Chairman Dave Camp (R-MI) unveiled his comprehensive tax reform proposal. Chairman Camp released his proposal in discussion draft form, and the bill was not officially...more

Taxation of Carried Interest Under Chairman Camp’s Tax Reform Proposal

On February 25, 2014, House Ways and Means Committee Chairman Dave Camp (R-MI) issued a sweeping tax reform discussion draft, numbering almost 1,000 pages (the Discussion Draft). This alert summarizes proposals included in...more

Proposed Tax Code Overhaul Introduced with the Tax Reform Act of 2014

On February 26, 2014, House Ways and Means Committee Chairman Dave Camp released draft (the "Discussion Draft”) that would substantially reform the current U.S. Tax Code (the “Code”). The Discussion Draft contains numerous...more

MT File re: 2014 Federal Budget, File No.: 990001-100

The mineral exploration tax credit has been extended for a further one-year period. This provides a 15% tax credit for flow-through share investors. Other items which would impact the mining industry include amendments to...more

New Urgency for Corporate Inversion Transactions (Quorum, March 2014)

Corporate inversions have constituted an active and successful part of the M&A market in 2013 and early 2014, as acquirors have typically traded up on the date of announcement. However, there is now a new urgency for U.S....more

PEA PME-ETI: An Enhanced Version of the French PEA of Interest for EU Asset Managers

A new French tax law, effective since the beginning of this year, has generated much excitement by creating an enhanced favorable tax regime – the PEA PME-ETI – for individual investors. The new regime is similar to the Plan...more

International Tax News - March 2014

NETHERLANDS: TAX TREATMENT OF HYBRID FINANCE INSTRUMENTS IN THE WAKE OF TWO LANDMARK CASES - The Dutch Supreme Court has given its judgment in two landmark cases regarding the classification of hybrid finance...more

Rev. Proc. 2014-24 Provides Taxpayers Relief When Missing Form 1122 On Joining A Consolidated Group

On March 10, the IRS released Revenue Procedure 2014-24, establishing the rules for when the IRS will automatically determine that a subsidiary corporation that had failed to file a properly and timely executed Form 1122,...more

UK Budget 2014: corporate, finance and real estate tax highlights

We set out below a summary of key items of interest announced by the UK’s Chancellor in the Budget on 19 March 2014 relating to businesses, corporate and finance taxation and real estate taxation. Much of what was announced...more

Proposed Section 752 Regulations Would Prohibit Bottom Guarantees And Impose Net Worth Requirements In UPREIT Transactions

The IRS has recently proposed regulations under Section 752 of the Code which, if finalized in current form, would radically change the use of guarantees in partnership transactions. Under these regulations, bottom guarantees...more

Spain amends tax treatment of debt restructuring

As a result of a substantial reform of the Insolvency Law, starting January 1, 2014 the tax treatment of debt restructuring modifies both Spain's Corporate Income Tax Law and its stamp duty regulations....more

Singapore aims to promote business by enhancing corporate tax incentives: key points in one chart

Singapore’s government, faced with an environment of rising business costs due to near full employment and escalating rents, has proposed enhanced incentives intended to support business transformation and upgrading, in...more

2014 U.K. Budget: Impact on Alternative Asset Managers

Chancellor George Osborne delivered his fifth coalition Budget today. In a wide-ranging statement, there are a significant number of tax-focused proposals that will make changes across the U.K. tax system. Some of these...more

Camp Tax Reform Proposal Could Impact Executive Compensation

On February 26, 2014, U.S. House of Representatives Committee on Ways and Means Chairman Dave Camp (R-MI) released the proposed Tax Reform Act of 2014 (the Camp Proposal), which would simplify the Internal Revenue Code and...more

Focus on Tax Controversy - Spring 2014

Company Jet Audit Issues: A Word to the Wise - Once a business attains a certain level of success, an aircraft often becomes a valued asset. Public and closely held private companies alike find that the use of a...more

Pennsylvania Corporations to Fund State Spending Increase

On February 4, Governor Corbett proposed his 2014-2015 budget, keeping his promise not to increase taxes, despite a nearly $1 billion proposed increase in spending. However, the budget includes a $150 million increase to...more

Automatic Consolidated Return Elections

Corporations that are directly or through intervening chains of corporations owned 80% or more by a common parent corporation can file a consolidated income tax return. There are many benefits to such returns, including...more

Spotlight on Alabama: Legislature Passes Two Pro-Business Tax Acts

Earlier this month the Alabama Legislature passed two pro-business tax acts. Both acts received the support of various business groups in the state. The first has already been signed into law by Governor Bentley, and we...more

Inside the New York Budget Bill Part Four: Nexus

This installment of Inside the New York Budget Bill examines the Budget Bill’s nexus provisions. Although these provisions may have limited impact on current New York taxpayers, they will significantly affect corporations...more

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