Corporate Taxes

News & Analysis as of

IRS Ruling Creates Opportunities for Tax Savings by Companies With Substantial Real Estate Assets

On July 29, Windstream announced that it plans to spin off certain telecommunications network assets into an independent, publicly traded real estate investment trust (REIT). Windstream made the announcement after it obtained...more

Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal  [Video]

In this interview with The Deal’s Jon Marino, Pepper Hamilton LLP's Joan Arnold, a partner who heads the firm's tax group, says Pfizer’s play for AstraZeneca isn’t the only inversion deal being sought. There are no shortages...more

Summary of IC-DISC Tax Benefits

Interest-Charge Domestic International Sales Corporations (“IC-DISCs”) offer significant potential tax benefits for U.S. companies that export U.S. manufactured products or certain engineering or architectural services with...more

California Tax Developments - A Reed Smith Quarterly Update (2nd Quarter 2014)

Case Updates - California’s taxing agency gets reprimanded again; ordered to pay $2.6 million in attorneys’ fees. We previously reported on the Los Angeles Superior Court case Lucent Technologies, Inc., et al. v. Board...more

‘F’ Reorganization Is Not An Inversion Transaction

The hot tax policy discussion these days is about corporate inversions. Rather than entice capital to stay in the U.S. with favorable tax rates (i.e., using the carrot), it is being proposed to enhance corporate inversion...more

U.S. Tax Developments Affecting Financial Institutions and Products

Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section...more

Are REITs a Viable Strategy for Communications Companies?

Windstream Holdings, Inc. recently announced plans to spin off its copper, fiber and other fixed real estate assets into an independent publicly traded real estate investment trust (REIT). Windstream received a private letter...more

The Corporate Inversion: From Obscure Strategy to Hot Trend

Capitalist ideals of “free enterprise” and “competition” make great debate topics, but when compared to the business-friendly tax codes of other nations the United States Tax Code cannot compete. With the highest corporate...more

New York Corporate Tax Reform: Benefits (and Burdens?) for Qualified New York Manufacturers

Earlier this year, New York enacted sweeping corporate tax reform that included a number of special benefits for qualified New York manufacturers. (For a discussion of this corporate tax reform, see our Special Report.) ...more

From Here to Eternity or San Juan! - Transitional Tax Planning with Pre-IPO or Appreciating Closely Held Stock

Speaking of Eternity, I must admit that I am a big fan of gospel music. While I like old school or traditional gospel, I prefer the newer R&B urban sound popularized beginning with Andrew Crouch and later Fred Hammond and...more

Thinking of Moving to Florida? Maybe a Little Further South is a Better Option

In an effort to revitalize its economy, Puerto Rico has passed tax laws intending to attract investment to the island. Located two hours from Florida, the Caribbean territory of the U.S. offers several substantial tax...more

EU Adopts a Parent-Subsidiary Directive Amendment on Hybrid Loans

On July 8th 2014, the European Union’s Economic and Financial Affairs Council (ECOFIN) adopted an amendment to the Parent-Subsidiary Directive (PSD). This amendment is targeted at cross-border hybrid loans and aims to...more

Private Fund Update - August 2014

In this issue: - The 113th Congress - The Administration - Securities and Exchange Commission - Association for Corporate Growth (ACG) - Small Business Investor Alliance (SBIA) -...more

Reed Smith Wins Toyota Credit Case in New Jersey Tax Court

On Friday, August 1, in a corporation business tax case handled by Reed Smith, the New Jersey Tax Court ruled that Toyota Motor Credit Corp. was entitled to recompute its tax by reducing gains on the sale of leased vehicles....more

Cahiers de droit fiscal international: Ukraine Cross-border outsourcing - issues, strategies and solutions

Summary and conclusions - Ukraine is experiencing the fast development of outsourcing industry due primarily to IT outsourcing. This is supported by tax incentives introduced for the IT sector. Ukrainian tax...more

CRS Report Takes Negative View on Bonus Depreciation

The Congressional Research Service (CRS) has issued a report analyzing the economic effects of bonus depreciation. CRS has very little to say that is positive about bonus depreciation. CRS views it as neither an effective...more

New York State Corporate Tax Law Reform: The Impact on Companies Providing Digital Products

On March 31, 2014, Governor Cuomo signed into law legislation that provides for an extensive reform of the state's corporate tax regime (the "Act"), most notably for out-of-state corporations providing digital products to New...more

FDIC Issues Guidance on Requests by Banks That Are S-Corporations for Dividend Exceptions to Capital Conservation Buffer

The FDIC issued guidance (the “Guidance”; FIL-40-2014) to banks and savings associations that have elected S-corporation tax treatment (collectively, “S-corporation Banks” and each an “S-corporation Bank”) concerning the...more

Favorable Ruling: Taxability of HMOs Under New York City General Corporation Tax

A New York City Tax Appeals Tribunal Administrative Law Judge (ALJ) recently ruled in favor of Aetna, Inc. (Aetna) on whether a health maintenance organization (HMO) was “doing an insurance business” in New York State,...more

New York Releases Corporate Tax Reform FAQs

Earlier this year, New York enacted sweeping corporate tax reform, generally effective for tax years beginning on or after January 1, 2015, including a new economic nexus standard, changes to New York’s combined reporting...more

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

Allied Domecq: Nexus-Combined Reporting

In Allied Domecq Spirits & Wines USA, Inc. v. Commissioner of Revenue, the Massachusetts Court of Appeals held that the parent company of a Massachusetts taxpayer could not be included in the taxpayer’s Massachusetts...more

Netherlands: New decrees on ATRs, APAs and substance requirements

One of the most attractive features of doing business in the Netherlands is the possibility to obtain an Advance Tax Ruling (ATR) and/or Advance Pricing Agreement (AP) so that foreign companies investing in or through the...more

Anti-Inversion Legislation May Impact Non-Inverted Private Equity Deals

Corporate inversions have been the target of regulatory or statutory tax proposals for many years. However, the recently attempted combination of Pfizer and AstraZeneca received prompt and more far-reaching attention in the...more

FTB Issues Legal Ruling Addressing Filing And Franchise Tax Obligations of LLCs And Their Members

I’ve written several posts on discussing the meaning and ramifications of “doing business” for California tax purposes. See, e.g., Why Your LLC May Be Doing More Than You Think In California Even When It’s Doing Nothing, 60...more

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