Corporate Taxes

High Net Worth Family Tax Report, Vol. 8, No. 2 -- May 2013

by Loeb & Loeb LLP on 5/18/2013

President’s fiscal year 2014 budget contains numerous tax provisions - President Barack Obama released his proposed budget for the government’s fiscal year 2014 on April 10, 2013, and, not surprisingly, the budget...more

"Shares for Rights: Over-Sold or Under-Appreciated?"

by James Anderson, Helena Derbyshire | Skadden, Arps, Slate, Meagher & Flom LLP on 5/14/2013

In this article we consider some alternative approaches to the proposed U.K. status of “employee shareholders,” who receive capital gains tax-exempt shares in their employer (or its parent) in return for waiving certain...more

At Last: Final Regulations Issued Under Section 336(e)

by Dennis Allen, Robert S. Chase II, Reginald Clark, Jeffrey Mace, Daniel McKeithen, Michael Miles, William Pauls, David Roby, Jr., Christopher Schoen, William Sheumaker, Carol Tello, more +H. Karl Zeswitz, Jr. | Sutherland Asbill & Brennan LLP on 5/14/2013

In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final regulations under §336(e) (the Final Regulations) on May 10. Section 336(e)...more

Corporate Suspension Blocks Tax Court Access

by Charles (Chuck) Rubin on 5/13/2013

Most states will suspend or involuntarily dissolve a corporation if it does not pay local taxes or fees. Such suspensions and dissolutions can typically be reversed after the corporation files to be restored and pays any back...more

Carrying on Business in Canada

by Heenan Blaikie LLP on 5/3/2013

In This Publication: - Preface - General Information - Immigration - Investment Factors - Intellectual Property - Principal Forms of Business Entities - Taxation -...more

The UK Patent Box – Clawing Some Money Back from the Taxman

by Anne Campbell, David Wraige | Mintz Levin - Intellectual Property on 4/18/2013

As of April 1st, companies paying UK corporation tax can take advantage of a new tax regime, dubbed the “Patent Box,” to reduce their tax burden. Here we explain why this new regime has been put in place and how and why it...more

Important Tax, Securities and Formation issues associated with LLCs, S Corps and C Corps

by The R. Bernard Law Group on 4/18/2013

One of the first hurdles an entrepreneur has to clear when starting a business is which entity type to choose when registering her business. There are many forms to choose from with different tax implications and different...more

Doing Business in the U.S.

In This Issue: - Preface - Chapter 1 Choice Of A Business Entity - Chapter 2 Introduction To Federal Securities Laws - Chapter 3 From Let’S Go Shopping To Closing: U.S. M&A Process - Chapter 4...more

A Month in UK Employment Law - April 2013

by Peta-Anne Barrow, Daniel Ornstein, Jennifer Wheater | Proskauer Rose LLP on 4/16/2013

It has been a busy period for those involved in drafting employment legislation. In our January 2013 edition, we summarised various expected changes to employment law. Since then, these changes have been debated and...more

Tax Bills Take Center Stage

by John Knapp | Winthrop & Weinstine, P.A. on 4/15/2013

On Thursday of this week, the Senate Tax Reform Division adopted its recommendations for the Senate Omnibus Tax Bill. Much of the attention on that bill focused on the proposed reduction in the State sales tax from 6.875% to...more

In Time of Austerity, President’s 2014 Budget Prioritizes Clean Energy Funding

by Bryan M. Stockton | Mintz Levin - Energy & Clean Technology on 4/11/2013

After two months of delay, the Obama Administration released its proposed 2014 budget on April 10. The 244-page document outlines the President’s spending priorities for the coming fiscal year. The proposal calls for $1...more

Tax Court Of Canada Appeal Of Large Corporation Thwarted By Wording Of Objection

by Cheryl Gibson | Dentons on 4/11/2013

Since 1995, the Large Corporation Rules found in subsections 165(1.11), 169(2.1) and 152(4.4) of the Income Tax Act (Canada) have applied to discourage large corporations from objecting to tax assessments as a means of...more

Liability of Directors in Canada – An Excerpt

by Ellyn Law LLP on 4/10/2013

This article is an excerpt of the Canada Chapter of International Liability of Corporate Directors, 2nd edition, published by Juris Publishing in February 2013. This excerpt excludes numerous aspects of the full chapter,...more

Readjustment of Taxation of Free Floating Dividends and of Fiscal Unity – Current Legislative Procedures

by Valentina Farle, Rainer Schmitt | K&L Gates LLP on 4/2/2013

Reform of taxation of free floating dividends for corporate income tax purposes The German Parliament (Bundestag) and the German Federal Council (Bundesrat) reached an agreement regarding the taxation of free floating...more

India at the Crossroads

by A. Tracy Gomes | McDermott Will & Emery on 3/26/2013

India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more

Tax Measures in 2013 UK Budget

by E.S. Kate Habershon, Katerina Heal | Morgan Lewis on 3/22/2013

UK government supports businesses, focusing on the UK's competitiveness while clamping down on tax avoidance and evasion. On 20 March, UK Chancellor of the Exchequer George Osborne released the UK's 2013 budget. The...more

Florida Applications for Research Credit May Be Submitted Starting March 20

by William Townsend | Fowler White Boggs P.A. on 3/19/2013

The first day to submit applications for the new Florida Research Credit is March 20, 2013. Applications will be reviewed by the state on a first-come, first-served basis, so timely filing is important. Emergency Rule...more

Florida Legislature 2013 Pre-Session Report

by Michael Abrams, David Roberts, Monica Rodriguez | Akerman Senterfitt on 3/6/2013

The Florida Legislature will begin its 60 day annual regular session of passing new laws and regulations on March 5, 2013 and conclude on May 2, 2013. The major legislative issue areas the Florida Legislature will consider in...more

Like Elmer Gantry, Supreme Court Breathes New Life Into Revivals

by Keith Paul Bishop | Allen Matkins Leck Gamble Mallory & Natsis... on 3/6/2013

The state, of course, likes to see corporations pay their taxes. When a corporation fails to do so, “the corporate powers, rights and privileges of a domestic taxpayer may be suspended, and the exercise of the corporate...more

Add-Back Legislation Reintroduced

by James Fritz | McNees Wallace & Nurick LLC on 2/28/2013

Representative Dave Reed (R-Indiana Co.), with more than fifty co-sponsors, has reintroduced legislation (H.B. 440) that would require corporations preparing PA Corporate Net Income Tax returns to add-back any “intangible...more

PA Governor Proposes Corporate Tax Cuts & Fuel Tax Increases

by James Fritz | McNees Wallace & Nurick LLC on 2/28/2013

Pennsylvania Governor Tom Corbett has proposed significant corporate tax cuts and fuel tax increases as part of his proposed 2013-14 budget, presented on February 5th. The General Fund budget would be increased by 2.4%, to...more

New Caledonia Investment Guide - Baker & McKenzie

by Emmanuel Guillaume, Mathieu Hanaut | Baker & McKenzie Australia on 2/27/2013

In This Issue: New Caledonia - an overview; Company law; Mining law; Environmental law; Immigration; Employment; and Overview of the New Caledonian tax system. Except from New Caledonia - an overview: -...more

Administrative Law Judge Affirms Holding on Alabama SRLY Rule

by Christopher Grissom, James Long | Bradley Arant Boult Cummings LLP on 2/26/2013

On August 15, 2012, Chief Administrative Law Judge Bill Thompson issued his long-awaited SRLY ruling, holding that an Alabama consolidated group was entitled to carry forward certain net operating losses (“NOLs”) incurred...more

Proposition 39 – Analysis and Status of Implementation Current as of: 2/14/13

by Constantine Baranoff | Kronick, Moskovitz, Tiedemann & Girard on 2/22/2013

In November 2012, Proposition 39 was approved by the voters of California. Prior to Proposition 39, corporations were given two options to calculate their state tax liability under California law. Proposition 39 eliminated...more

International Tax & Transfer Pricing Strategies in the Crosshairs

by Claire M.C. Kennedy | Bennett Jones LLP on 2/22/2013

The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more

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