Corporate Taxes

News & Analysis as of

Tax Court Allows Deduction for Advisory Fees in M&A Transaction

The Tax Court of Canada has recognized in a recent case that “oversight expenses” – notably investment banking and other professional advisory fees for services rendered to boards of directors in their discharge of oversight...more

UK Government Confirms Introduction of New Cap on Interest Deductibility

The UK Government has recently confirmed that it will be introducing a new cap on interest deductibility. Under the new rule, the ability of groups to obtain tax relief for interest will be limited by reference to a ratio of...more

Development of the practice of charging the person beneficially entitled to income additional tax when income is paid to foreign...

On 11 July 2016 the Commercial Court of Moscow rendered a decision in case No. ?40-442/15-39-2 under the claim of Credit Europe Bank CJSC (the “Bank”). That decision is yet another judgment on the subject of applying the...more

Reasonable Compensation Issues Remain On the IRS Radar Part II: S-Corporation Concerns

Our May 26, 2016 article, Reasonable Compensation Issues Remain on the IRS Radar ("Part I"), discussed how the IRS scrutinizes the reasonableness of compensation payments made to C-corporation shareholder-employees. As...more

Safe Harbor Acquisition of Control for Spin-Offs

Code Section 355, and related Code provisions, when applicable, will allow a corporation to spin-off or split-off a subsidiary corporation to its shareholders without triggering gain to the corporation or its stockholders....more

Proposed Regulations Would Block Some Spinoffs

Proposed regulations issued on July 14, 2016 generally would prevent tax-free spinoffs involving companies with less than 5% active business assets and spinoffs where one company holds a substantial amount of nonbusiness...more

Five Things about the IRS’s Proposed Regulations on the Spinoff Device and Active Business

On July 14, 2016, the Internal Revenue Service (IRS) proposed long-anticipated regulations tightening the “device” and “active trade or business” tests that are necessary for a corporation to distribute a subsidiary in a...more

Pennsylvania Enacts Tax Bill as Part of Budget Package

Pennsylvania has enacted tax law changes projected to generate $752M in new revenue. The changes include severe restrictions on the vendor sales tax discount for timely filing, imposition of sales tax on digital downloads and...more

Brexit and Other Key Issues for CFOs and Corporate Treasurers

On June 23, 2016, the UK electorate voted to leave the European Union in an advisory Referendum. We expect the UK Government to commence negotiations to withdraw and to establish a framework for the UK’s new relationship with...more

What Does Brexit Mean for UK Tax?

Once the formal procedure under Article 50 of the Lisbon Treaty is initiated by the United Kingdom, the government will negotiate the terms of its exit from the European Union. Whilst we must accept that this is a period of...more

Significant developments in Canadian carbon legislation and policy

On June 6, 2016, Alberta passed the Climate Leadership Implementation Act, creating a carbon levy on fuel consumption. This legislation marks the provincial government’s first step towards executing its Climate Leadership...more

Major Tax Legislation Enacted by the Short Session of the 2015-16 General Assembly

This Alert summarizes the major tax provisions included in legislation passed by the 2015-2016 North Carolina General Assembly in its short session, which concluded earlier this month. The most widely discussed tax...more

Determination Letter Rationing: IRS Reveals the Brave New World

Last year’s announcement by the Internal Revenue Service (IRS) of the elimination of the current five-year remedial amendment cycle system for determination letter approval of restated individually-designed qualified plan...more

Development of court practice on tax disputes over compensation payments to employees due to company relocation

On 17 June 2016 the Commercial Court of Moscow rendered a decision on the Gazprom Neft OJSC case, No. ?40-2476/16-108-19 (the “Decision”)....more

MoFo New York Tax Insights - Volume 7, Issue 7

ALJ holds NYS Real Estate Transfer Tax Cannot Be Imposed on Sale of 45% Membership Interest in LLC - In an issue of first impression under the New York State real estate transfer tax, a New York State Administrative Law...more

Long-Awaited Alabama Tax Amnesty Program Kicks Off

Beginning June 30 and running through August 30, the Alabama Department of Revenue (ADOR) is offering many taxpayers an opportunity to come forward voluntarily and pay a litany of delinquent state and state-administered local...more

"Proposed Treasury Regulations Revolutionize Tax Rules Governing Intercompany Financing Transactions"

Recently proposed Treasury regulations, which will likely be finalized this year, promise to alter the tax treatment of a wide range of intercompany financing transactions dramatically, upending nearly a century of law...more

Revolutionary changes in Polish Tax Law: Introducing a General Anti-Avoidance Rule

Starting from 15 July 2016, a new GAAR(General Anti-Avoidance Rule) clause will be introduced into the tax system in Poland. The new clause may have a significant impact not only on future transactions, but also on the...more

Brussels Tax Alert

A. Beneficial tax regime - Law 89/1967 "On the Establishment in Greece of Foreign Commercial and Industrial Companies" was meant to attract foreign investments in Greece, by providing a wide range of benefits regarding...more

What are the Tax Consequences of BREXIT for U.S. Taxpayers?

Recently, The Harvard Law School Forum on Corporate Governance and Finance published a note titled "The Legal Consequence of Brexit, authored by Simon Witty. We have restated the transactional tax commentary here. We have...more

Anatomy of a Busted Tax Rescue Transaction

For many years, there were companies out there that marketed a service to tax professionals to help their corporate clients with large tax liabilities. I remember receiving solicitations to think of them if I came across...more

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

Five Ways that Brexit Will Complicate Cross-Border M&A

This week's referendum in the UK and the decision for Great Britain to exit the European Union (EU) has caused turmoil in financial markets. For M&A practitioners, however, the impact is only just beginning. Below are five...more

Brexit: Keep Calm and Carry On?

Does the United Kingdom’s vote to leave the European Union change the United Kingdom’s attractiveness as a holding company jurisdiction?...more

"Insights: Brexit"

On June 23, the UK electorate took the historic decision to leave the European Union, a process that has never been undertaken by any member state. While the vote itself does not trigger the process of exit from a legal...more

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