News & Analysis as of

International Tax News - July 2014

BITCOIN FORGES AHEAD: 3 QUICK LOOKS - Bitcoin is a decentralized peer-to-peer payment system that exists virtually and is unlimited by the constraints of countries, government or time. In an age when business leaps...more

Tax “Brujeria” - Transitional Tax Planning Considerations to Move Your Business to Puerto Rico

The other day I asked the garage attendant who was of Puerto Rican (PR) ancestry and listening to Salsa music as she worked, which group was the most influential band in her estimation – La Sonora Poncena or El Gran Combo....more

Analysis: The Tax And The City Briefing For July

Redemption payments - The Court of Appeal (CA) has made short work of a case where loan stock was issued without interest but with a right to redemption proceeds of 7.25% per annum on the principal amount. The outcome...more

Michigan Supreme Court Upholds the Compact Election

On July 14, 2014, the Michigan Supreme Court in a splintered 3-1-3 decision found in favor of IBM’s election to apply the Multistate Tax Compact’s three-factor apportionment formula to the now-repealed Michigan Business Tax...more

Oil Severance Tax Law (SB 1017) Dies in the Senate Appropriations Committee

Last Friday, May 23, 2014, Senate Bill 1017, the Oil Severance Tax Law, failed to pass through the Senate Appropriations Committee. As a result, the bill is effectively dead for the year. SB 1017 was introduced by Senator...more

New York State Tax Reform Update

Qualified manufacturers subject to the New York State Business Corporation Tax may now pay no tax on business income earned in New York....more

IRS Changes Position on Certain Income Earned by State-Chartered Credit Unions

In a recent memorandum (found here), the IRS issued instructions to all exempt organization examiners on the applicability of unrelated business income tax (“UBIT”) to certain income earned by state-chartered credit unions...more

Taking Off the Gloves: Tax and Revenue Law Change Proposals We Expect to See in the Short Session

Between legislative sessions the Joint Legislation Commission on Revenue Laws meets to determine how to handle tax and finance issues including repeals, clarifications and new proposals. We expect the following bills to be...more

The First Dish is Served: Chairman Camp Unveils Comprehensive Tax Reform Discussion Draft

On February 26, 2014, House Ways and Means Committee Chairman Dave Camp (R-MI) unveiled his comprehensive tax reform proposal. Chairman Camp released his proposal in discussion draft form, and the bill was not officially...more

Taxation of Carried Interest Under Chairman Camp’s Tax Reform Proposal

On February 25, 2014, House Ways and Means Committee Chairman Dave Camp (R-MI) issued a sweeping tax reform discussion draft, numbering almost 1,000 pages (the Discussion Draft). This alert summarizes proposals included in...more

Proposed Tax Code Overhaul Introduced with the Tax Reform Act of 2014

On February 26, 2014, House Ways and Means Committee Chairman Dave Camp released draft (the "Discussion Draft”) that would substantially reform the current U.S. Tax Code (the “Code”). The Discussion Draft contains numerous...more

MT File re: 2014 Federal Budget, File No.: 990001-100

The mineral exploration tax credit has been extended for a further one-year period. This provides a 15% tax credit for flow-through share investors. Other items which would impact the mining industry include amendments to...more

Proposed Section 752 Regulations Would Prohibit Bottom Guarantees And Impose Net Worth Requirements In UPREIT Transactions

The IRS has recently proposed regulations under Section 752 of the Code which, if finalized in current form, would radically change the use of guarantees in partnership transactions. Under these regulations, bottom guarantees...more

2014 U.K. Budget: Impact on Alternative Asset Managers

Chancellor George Osborne delivered his fifth coalition Budget today. In a wide-ranging statement, there are a significant number of tax-focused proposals that will make changes across the U.K. tax system. Some of these...more

Automatic Consolidated Return Elections

Corporations that are directly or through intervening chains of corporations owned 80% or more by a common parent corporation can file a consolidated income tax return. There are many benefits to such returns, including...more

Spotlight on Alabama: Legislature Passes Two Pro-Business Tax Acts

Earlier this month the Alabama Legislature passed two pro-business tax acts. Both acts received the support of various business groups in the state. The first has already been signed into law by Governor Bentley, and we...more

Legal Alert: Court Holds Comcast Did Not Establish Unitary Relationship with QVC

Yesterday the Los Angeles Superior Court held that Comcast did not establish a unitary relationship with its 57% owned subsidiary, QVC. The court found for Comcast and held that the evidence presented at trial demonstrated...more

Court Hears Oral Argument in New Jersey Partnership Nexus Case: Tough Questions for Division of Taxation

Earlier this week, a New Jersey appellate court heard oral argument in BIS LP, Inc. v. Director, Div. of Taxation, which is the lead case addressing the issue of whether a corporate limited partner is taxable on its...more

Proposed Carried Interest Legislation Takes A Different Approach

On February 26, 2014, U.S. Rep. David Camp (R-MI), chairman of the House Ways and Means Committee, released a draft of the Tax Reform Act of 2014 (TRA 2014), which would provide for the most significant tax reform since the...more

IRS Revises Directive on IDR Issuance and Enforcement Process

On February 28, 2014, the Internal Revenue Service Large Business and International Division released updated guidance for examiners incorporating and superseding two directives relating to Information Document Requests. The...more

Representative Dave Camp’s Proposed Draft Legislation on Tax Reform

Last week, Representative Dave Camp (R-MI), Chairman of the House Committee on Ways and Means, unveiled draft legislation on tax reform that would include a 10 percent tax on municipal bond interest for joint filers with...more

Potential Impact of the Tax Reform Act of 2014 on Insurance Companies

On February 26, House Ways and Means Committee Chairman Dave Camp (R-Mich.) released a “Discussion Draft” of the Tax Reform Act of 2014, which sets forth his much-anticipated tax reform proposals. Of note, the Discussion...more

Comparison of Typical MLP and Yieldco Structures

The rise of master limited partnerships (MLPs) as an asset class has coincided with investors’ desire for stable and growing cash flow. In 2013, there were 21 initial public offerings (IPOs) of MLPs and more are on the way in...more

Proposed Regulation Incorporates IRS Litigation Position on UBTI for VEBAs and SUB Trusts

On February 6, 2014, the Internal Revenue Service (IRS) proposed new regulations for calculating the unrelated business taxable income (UBTI) of IRC section 501(c)(9) voluntary employees’ beneficiary associations (VEBA) and...more

Massachusetts “Tech Tax” Abatement Applications Due December 31, 2013

In September 2013, Massachusetts enacted legislation to retroactively repeal the extension of the 6.25 percent Massachusetts sales and use tax to certain types of computer system design and software modification services...more

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