Mitchell A. Newmark is a partner at Morrison & Foerster LLP and is concentrated on state and local tax litigation and appeals before administrative and judicial bodies around the country. Newmark also advises companies and...more
- Both the U.S. House and Senate are floating proposals to close a loophole that allows tax deductions when there is a question of whether a fine is punitive.
- Debate centers on whether the deduction...more
The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of recent legislation around the U.S....more
Chairman Max Baucus has issued a discussion draft that offers some interesting and provocative proposals on corporate international tax reform. Designed to “reform international tax rules to spark economic growth, create...more
In This Issue:
- The true cost of fines: Bills would address tax break for corporate fines
- Senate approves new protection for criminal antitrust whistleblowers
- Justice Department sinks ex-Navy...more
Earlier this week, Senators Mary Landrieu (D-La.) and Susan Collins (R-Maine) lent their support to a revamped version of the Master Limited Partnerships Parity Act. The bill was reintroduced earlier this year by Senators...more
The strategic geographical position of the country and the membership with the European Union provide a wide range of investment opportunities in Bulgaria not only for local, but for foreign investors as well. The advanced...more
Section 355 is one of the few bright spots remaining for corporate tax planners since repeal of the General Utilities doctrine in the mid-1980s. However, the tax-free treatment of corporate spin-offs and other separations...more
I. Introduction and Executive Summary -
This paper examines the effects of a switch in the U.S. corporate tax system from the current worldwide tax system with deferral to a territorial tax system consistent with those...more
Colleagues and Friends,
It is with great pleasure that we circulate to you the inaugural edition of T he Oklahoma MLP Quarterly — a publication focused on master limited partnerships, or MLPs, in our great state....more
On November 4, 2013, the Internal Revenue Service released an internal directive that completes a two-part process of reshaping the dynamic between taxpayers and IRS examiners during the information-gathering phase of an...more
The list of Non-Cooperative States has been expanded to include Jersey, Bermuda and the British Virgin Islands. As from 1 January 2014, sums paid into these states are subject to a withholding at the source of 75% and are no...more
Earlier this week, the New Jersey Tax Court released a letter opinion in Whirlpool Properties Inc. v. Director, its latest decision involving throwout. The Division of Taxation had argued that there were unresolved factual...more
I am pleased to present to you DLA Piper’s “Doing Business in Japan” Guide.
Japan is the world’s third largest economy and remains cutting-edge in business. In 2012, 68 Global 500 Companies were headquartered in...more
Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted through wholly-owned foreign subsidiaries.
Originally Published in Law360 - October 29,...more
A U.S. shareholder of a controlled foreign corporation (CFC) has gross income on its share of the CFC's subpart F income. This income includes “foreign base company sales income” or FBCSI. ...more
Pass-through structures -
Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries....more
Introduction: Why Post-Issuance Compliance?
Over the past few years, the tax-exempt bond market has been under heightened scrutiny by various regulators, including the Internal Revenue Service...more
In a period of 18 months, three state courts have refused to extend economic nexus approaches to the facts before them, despite prior decisions in those states that corporations without physical presence...more
Welcome to the Reed Smith Massachusetts State Tax Quarterly Update for the 3rd Quarter of 2013. This update includes coverage of the repeal of the short-lived software services tax and pending litigation on other...more
The China (Shanghai) Pilot Free Trade Zone (PFTZ) officially launched on September 29th, granting 25 Chinese and overseas companies licenses to register in the PFTZ on its first day. The General Plan for the PFTZ was...more
The following sets out a summary of recently announced major changes affecting the transfer pricing policy of certain French companies.
New Provisions of French Law -
Provisions Already Adopted -
Amid the intense dispute over federal spending and debt, the chairmen of the tax writing committees in the US Senate and the House of Representatives continue their efforts to build a consensus among their members for tax...more
Tax experts in Switzerland now predict that certain Swiss tax regimes – the cantonal tax regime, the holding regime and, in particular, the auxiliary company regime, will ultimately need to be repealed.
A repeal of...more