Corporate Taxes

News & Analysis as of

Taxpayer Overcomes New Jersey Amnesty Penalty

The Supreme Court of New Jersey recently affirmed a decision that amnesty and late-filing penalties did not apply to the taxpayers in United Parcel Serv. Gen. Servs. Co. v. Dir., Div. of Taxation, No. 072421 (N.J. Dec. 4,...more

The UK’s New Diverted Profits Tax

The UK Treasury has published the draft legislation for the new Diverted Profits Tax (DPT), which it plans to introduce from 1 April 2015. This has been unofficially described as the “Google Tax”, and represents part of the...more

Directors Need to Meet High Standard to Avoid Liability

The Tax Court of Canada again confirmed that directors of corporations will have a high burden to meet to establish a due diligence defence and avoid liability for unremitted source deductions....more

International Tax News - December 2014

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS - The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015. The government has published...more

Unfinished Business: Illinois General Assembly Fails to Repeal Self-Procured Insurance Tax

Despite a strong effort by a coalition of opponents, efforts to repeal the new Illinois self-procured insurance tax law in the veto session of the Illinois General Assembly were unsuccessful. As a result, the law will take...more

2014 Year-End Tax Update

I. A LOOK BACK AT 2014 TAX MATTERS: A. Some Random Observations - ..1. This year’s update is brought to you by the letter “I,” as in “inversions.” ..2. Tired of waiting for Congress to address what they...more

Alabama Tax Developments – 2014 Year in Review

This SALT Alert summarizes the major legislative, judicial, and administrative developments affecting Alabama business taxpayers with respect to income, transactional, and property taxes, as well as several updates on...more

Diverted Profits Tax – First Thoughts

The UK Government intends to introduce a 25% “diverted profits tax” (DPT) from 1 April 2015. The tax is designed to catch the artificial erosion of the UK corporate tax base by multi-nationals that avoid establishing a...more

“Deoffshorization” measures

On 24 November 2014 the Russian President signed Federal Law No. 376-FZ “On amending parts one and two of the Tax Code of the Russian Federation (in the part related to taxation of profits of controlled foreign companies and...more

Nevada Construction Law Developments in 2014

This is an off year for Nevada’s biennium legislative session; but even though the Legislature was quiet, Nevada’s electorate was not. Nevadans approved State Question No. 1 at the ballot box. This measure amends the Nevada...more

"UK Government Announces New 25 Percent Diverted Profits Tax"

On Wednesday, the U.K. Government released draft legislation to be effective on 1 April 2015, which will impose a “diverted profits tax” (DPT) at 25 percent of the amount of profits deemed to have been diverted from the U.K....more

UK Finance Bill 2015 -- Draft Clauses Published

Draft clauses of the UK Finance Bill 2015 were published on 10 December 2014. They will now be the subject of consultation until 4 February 2015. This Alert provides more details on the most significant measures contained in...more

U.S. Supreme Court Hears Arguments in 4-R Act Case (For the Second Time)

On December 9, the U.S. Supreme Court heard oral arguments in the last of three state and local tax cases that it accepted this term – Alabama Department of Revenue v. CSX Transportation, Inc. (CSX II), a case that had...more

MoFo New York Tax Insights - Volume 5, Issue 12 - December 2014

In This Issue: - ALJ Rejects New York City’s Attempt to Forcibly Combine Bank and Its Non-New York City Mortgage Subsidiary - Tribunal Amends Decision Upholding Disallowance of Nonresident Partner’s Loss from...more

Autumn Statement 2014

Yesterday, the Chancellor of the Exchequer delivered the UK 2014 Autumn Statement. Below we summarise some of the main announcements: Taxation of multi-nationals - Diverted profits tax (aka the "Google tax")...more

Tax Me Once - December 2014

A Creative – If Complex – Route to Tax Savings When Going Public For technology and other startups, going public can be doubly taxing—literally....more

PA Tax Law News - December 2014

In This Issue: - Recent PA Sales Tax Guidance Concerning Natural Gas and Other Mining Activities - Focus on Pennsylvania Corporate Taxes - Application and Sale of Restricted Tax Credits -...more

A new UK withholding tax exemption for privately placed debt

The Chancellor of the UK Exchequer, George Osborne, announced in the 2014 Autumn Statement on Wednesday a new targeted exemption from UK withholding tax for interest on qualifying privately placed debt. The exemption is a...more

Autumn Statement 2014

On December 3, 2014, George Osborne delivered his Autumn Statement. Traditionally, the purpose of this has been to update economic projections and department spending allocation, but increasingly it includes statements...more

2014 Extenders Clear the House

For many years now, Congress has contributed to tax uncertainty by extending certain favorable tax provisions on a year by year basis. Thus, for example, in 2014 these extenders have expired. Neither the IRS, who has to...more

Scheel-Utvalgets Utredning - Kapitalbeskatning I En Internasjonal Økonomi

Regjeringen Stoltenberg II nedsatte 15. mars 2013 et ekspertutvalg for å vurdere selskapsbeskatningen i lys av den internasjonale utviklingen. Den 2. desember 2014 la Scheel-utvalget frem sin innstilling. Innstillingen vil...more

UK: Autumn Statement- More good news for the creative sector

On 3 December 2014, as part of his Autumn Statement, the UK Chancellor announced the introduction of a new children’s TV tax relief which is due to be introduced from April 2015....more

UK Autumn Statement 2014

Today’s Autumn Statement saw financial institutions hit by a surprise proposal to limit the proportion of their profits which can be reduced by the carry forward of past losses, which will mean tax is paid on those profits...more

Autumn Statement 2014: Key Implications for U.K.-Based Alternative Asset Managers and Their Funds

Shortly after 12.30 p.m. today, the U.K. Chancellor of the Exchequer, George Osborne, delivered the last Autumn Statement before next year’s general election....more

Application and Sale of Restricted Tax Credits

The Pennsylvania Department of Revenue has issued detailed rules for the application and sale of various Pennsylvania tax credits. Corporation Tax Bulletin 2014-04 replaces Corporation Tax Bulletin 2011-03. The Bulletin...more

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