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ASKramer Law

Business Taxation of Hedging Transactions Part V: Consolidated Groups

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Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more

ASKramer Law

Business Taxation of Hedging Transactions Part III: Identification Requirements and Aggregate Hedging

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When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more

ASKramer Law

Business Taxation of Hedging Transactions Part II: Common Situations

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What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

McDermott Will & Emery

Weekly IRS Roundup January 1 – January 5, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 1, 2024 – January 5, 2024. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials

Tax of counsel Fred Goldberg and senior advisor for tax resolution strategies De Lon Harris, both formerly of the IRS, joined the hosts of “GILTI Conscience” for a comprehensive look at current developments at the agency,...more

Miller Canfield

IRS Announces Denials of Employee Retention Credit

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As described in our October 24 article “IRS Offers Forgiveness for Erroneous Employee Retention Credit Claims” the IRS has increased scrutiny on claims for the Employee Retention Credit (“ERC”). The IRS halted processing...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good

In our third installment of the “GILTI Conscience” pro bono spotlight series, counsel Jared Binstock and associate Sanessa Griffiths joined the podcast hosts to discuss how they’ve utilized their corporate tax backgrounds to...more

Shumaker, Loop & Kendrick, LLP

Did You Lose Your Security Interest in That Collateral? The New Way to Perfect Security Interests Using Updated UCC Forms

Beginning July 1, 2023, many states began accepting revised Uniform Commercial Code (UCC) forms to perfect security interests. These revised forms were adopted earlier this year by the International Association of Commercial...more

Blank Rome LLP

New Jersey Makes Substantial Changes to the Corporation Business Tax

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On July 3, 2023, New Jersey Governor Phil Murphy signed into law S.B. 3737 / A.B. 5323 (the “Bill”), which makes significant changes to the Corporation Business Tax (“CBT”). Some of the most noteworthy changes are summarized...more

Wilson Sonsini Goodrich & Rosati

Alternative Cash Management Strategies Should Not Have an Impact on Qualified Small Business Stock (QSBS) Status

In light of the banking crisis of 2023, many emerging growth and start-up companies have explored alternative cash management strategies, including holding cash in money market funds or investing in cash equivalents such as...more

Brownstein Hyatt Farber Schreck

Taxation and Representation, March 28, 2023

Treasury Department and IRS Release Preliminary Guidance on Semiconductor Tax Credit. On March 23, the Treasury Department and IRS published proposed regulations for implementing the new section 48D advanced manufacturing...more

A&O Shearman

Funding Rule Under Notice 2023-2 Expands the Scope of the Stock Buyback Excise Tax to Repurchases of Stock of Many Foreign...

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Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more

Stoel Rives LLP

Washington Supreme Court Upholds Capital Gains Tax

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Effective January 1, 2022, Washington law imposes a 7% tax on gains over $250,000 per year from the sale or exchange of long-term capital assets allocated to Washington such as stocks, bonds, business interests, or other...more

Burns & Levinson LLP

State Solutions to the “280E Problem”

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Does anyone else feel immense frustration when considering the inequitable treatment that cannabis businesses receive under Section 280E of the Internal Revenue Code (26 U.S.C. s. 280E)? It grinds my gears that our clients,...more

Brownstein Hyatt Farber Schreck

Taxation & Representation. Feb. 15, 2023

TAX TIDBIT - Progress on Werfel and Blatchford Appointments, Other Nominations Delayed. Following the retirement of former IRS Commissioner Chuck Rettig in early November 2022, the tax-administration agency has been...more

Stoel Rives - Mineral Law

Tax Actions by the Alaska Legislature in 2022

In my most recent column for State Tax Notes, I look at several bills that did and didn’t pass in the latest session of the Alaska State Legislature, which adjourned in May, and at what may be on the horizon....more

Brownstein Hyatt Farber Schreck

Taxation and Representation, July 12, 2022

Reconciliation Revival? Ever since Sen. Joe Manchin (D-WV) publicly renounced his support of the House-passed Build Back Better Act (BBBA) in December of last year, the prospects of a reconciliation bill have appeared grim...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, May 24, 2022

Tax Staffers Discuss State of Tax Policy. At a tax conference last week, top officials from the Biden administration and key congressional staffers discussed the latest in tax policy. One panel, which was focused on the...more

Miller Nash LLP

A Non-U.S. Company’s Guide To Doing Business in the U.S.: Understanding Federal Taxes

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The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust economy and a strong market for imported...more

Orrick, Herrington & Sutcliffe LLP

The UK Qualifying Asset Holding Company Regime - Highlights

The United Kingdom ("UK") Qualifying Asset Holding Company ("QAHC") regime (at Schedule 2 to Finance Act 2022) comes into force on 1 April 2022. The HM Revenue & Customs ("HMRC") policy paper dated 27 October 2021 states:...more

Freeman Law

Donkeys and Taxes

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Hobby Loss or Business Loss Tax Deduction - It’s not every day that a case comes through the Tax Court centered on the taxation of miniature donkey breeding. But the recent case of Huff v. Commissioner was focused on just...more

Freeman Law

So, The Texas Comptroller Says You Owe Tax—Now What?

Freeman Law on

It’s a letter that no one looks forward to—a notice of determination (also sometimes called a “Notification of Audit Results,” “Notification of Exam Results,” or “Notice of Tax/Fee Due”) from the Texas Comptroller of Public...more

Kohrman Jackson & Krantz LLP

2021 Tax Changes For Businesses: The Not So Good, The Bad And The Ugly

As small and mid-size business owners move toward the federal tax filing deadline in this new year, they need to be aware of certain changes in the federal income tax area. A short listing of the highlights (more...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

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On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Bennett Jones LLP

Alberta Proclaims New Legislation to Address Municipal Tax Arrears

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On December 8, 2021, Alberta proclaimed in force Bill 77, the Municipal Government (Restoring Tax Accountability) Amendment Act, 2021 (the Amending Act), which is intended to strengthen municipal budgets following reports by...more

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