Corporate Taxes Business Taxes

News & Analysis as of

A Comparison of Trump and House GOP Tax Reform Proposals

With Republicans in control of the U.S. Senate, the U.S. House of Representatives and the White House starting in 2017, the federal government is now better positioned to move forward on comprehensive tax reform, with...more

UK Autumn Statement 2016

This was Chancellor Phillip Hammond's first (and last) Autumn Statement. From Autumn 2017, there will be an Autumn Budget for the coming year, which will enable greater scrutiny of complex tax provisions, followed by a Spring...more

Corporate Tax Reform on the Front Burner?

There is a clue out there that President-elect Trump may first want to tackle corporate tax reform, before moving on to individual tax reform (both of which involve rate reductions). This is because Stephen Moore, a Heritage...more

What Kind of Tax Changes Can We Expect From Trump's Presidency?

The tears have not yet dried for some, and the celebrating is not yet over for others, but let's turn our attention to taxes. With a Republican Congress and a Republican president, some measure of tax relief is a given. What...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

U.S. Taxes and the 2016 Election: More of the Same on the International Front

When it comes to proposed tax reform, the devil is always in the details. Business Taxes - On the business tax front, Mr. Trump’s proposal lowers the corporate tax rate to 15% (from a maximum 35%), while Mrs....more

Is an S Election for an LLC Smart Planning or a Bad Idea?

By default, a limited liability company (“LLC”) with two or more members is taxed as a partnership. It also is possible to elect to treat an LLC as an S corporation for income tax purposes. But is it a good idea? And if an S...more

MoFo New York Tax Insights - Volume 7, Issue 8

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...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

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

Throwout: New Jersey Supreme Court Denies Certification

The New Jersey Supreme Court has denied certification in Lorillard Licensing Company LLC v. Director, Division of Taxation, making the Appellate Division's decision final. The Appellate Division affirmed the Tax Court in its...more

Rethinking Choice of Entity — Section 1202 Stock

We tax advisors spend plenty of time assessing whether a particular business is better suited operating as a flowthrough entity or as a tax-paying “C corporation.” Flow-through entities generally include sole...more

Federal Tax Overpayment & Underpayment Interest Rates–3rd Quarter 2016

Please see Charts below for more information....more

Connecticut Tax Developments

2016 Legislative Session: The New Economic Reality - In his February 2016 State of the State address, Governor Malloy announced that his administration would be adopting a new approach to state budgeting in light of...more

Make Sure the Corporation is in Good Standing Before Filing a Tax Court Petition

Many states will involuntarily or administratively dissolve a corporation for not paying or filing annual reports, fees, or tax returns. The ability of a dissolved corporation to engage in activities after dissolution depends...more

Legislation Revives and Permanently Extends 100% Gain Exclusion for Certain Sales of (C Corporation) Qualified Small Business...

For years now, conventional wisdom has been that, wherever possible, businesses should seek to operate as flow through entities (S corporations or partnerships) for income tax purposes. One rationale for this viewpoint has...more

Proposed Section 385 Regulations May Dramatically Impact Portfolio Debt Planning

On April 4, 2016, the IRS and Treasury issued proposed regulations under Section 385 (the “Proposed Regulations“). The Proposed Regulations, which were thought to have been a response to post-inversion earnings stripping...more

NYC Extends Tax Credit Available to Biotech Companies

In late 2015, New York City Mayor Bill de Blasio signed into law a three-year extension of NYC’s biotechnology tax credit. The credit, which was set to expire on January 1, 2016, is now available through December 31, 2018....more

Is it Debt or is it Not? Proposed Treasury Regulations Would Significantly Change Debt vs. Equity Analysis

Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the “Proposed Regulations”) under Section 385 of the Internal Revenue Code. The Proposed Regulations would significantly modify the tax...more

City of Philadelphia’s BIRT: Is 3-Factor Apportionment Still an Option for Your 2015 Return?

Philadelphia’s business income and receipts tax—the so-called “BIRT”—is imposed at a whopping 6.41% rate.1 Add that to the state-level corporate net income tax of 9.99%, and the combined tax rate on corporate income subject...more

The Delaware Competes Act Signed Into Law

This week, Delaware Governor Jack Markell signed into law HB 235, otherwise known as the Delaware Competes Act of 2016. HB 235 was passed by the Delaware State House of Representatives on January 14, 2016 and the Delaware...more

Several Key Business Associations Announce 2016 Tax Legislative Agendas

In preparation for the 2016 regular session, which begins on February 2, several of Alabama's key trade and business organizations recently announced their tax legislative agendas. As reflected in these agendas, the 2016...more

New Jersey Tax Court Publishes Decisions That Dual Nexus Standards Are Inappropriate For Throwout

On January 6, 2016, the New Jersey Tax Court approved its January 14, 2014 decision in Lorillard Licensing Company LLC v. Director, Division of Taxation for publication, making the Tax Court decision precedential. The...more

New Jersey Files Notice of Petition for Certification After Appellate Division Affirms That Dual Nexus Standards Are Inappropriate...

New Jersey filed a notice of petition for certification (request for discretionary review) with the New Jersey Supreme Court seeking reversal of the Appellate Division’s December 4, 2015 decision that the Division may not...more

2015 Year-End Tax Planning for Businesses

As 2015 draws to a close, there is still time to reduce your 2015 taxes and plan ahead for 2016. This advisory highlights several potential tax-saving opportunities for business owners to consider. ...more

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