News & Analysis as of

Tax Extenders for the 2014 Tax Year: A Holiday Tax Gift from D.C.

Just days before the 2014 tax season draws to a close, new legislation was enacted in D.C. to provide a one-year retroactive extension for over 50 tax benefits and incentives which had expired in 2014. The one-year extension...more

Congress Passes Tax Increase Prevention Act of 2014 and Retroactively Extends Tax Relief Provisions

Welcome Tax Relief Provided to Individuals and Businesses Extended through Calendar Year 2014 - The Tax Increase Prevention Act of 2014 retroactively extends, through Dec. 31, various individual and business tax relief...more

Currency Conversion Concerns: New York Issues Guidance on Virtual Currencies

On December 5, 2014, the New York Department of Taxation and Finance (Department) released TSB-M-14(5)C, (7)I, (17)S. This (relatively short) bulletin sets forth the treatment of convertible virtual currency for sales,...more

Tax Extenders Passed by Congress

The President signed legislation passed by Congress which retroactively extends from January 1, 2014 many individual and business tax provisions which otherwise expired at the end of 2013. The extension is only for 2014, so...more

Summary of the Tax Extenders in the Tax Increase Prevention Act

On Friday, December 19th, President Obama signed the Tax Increase Prevention Act (“TIPA”), H.R. 5771, into law. TIPA is commonly referred to as the “tax extenders” bill as it extends certain expiring provisions of the...more

Congress Approves Tax Extension Bill

TWO WEEKS ONLY! SAVE NOW! Congress has finally approved the extenders bill in what is widely viewed as terrible tax policy, but a welcome holiday gift nonetheless. The Tax Increase Prevention Act of 2014 extended a...more

Tax Extenders Signed into Law; Production Tax Credit Extended for Facilities Beginning Construction in 2014

Earlier today, President Obama signed the Tax Increase Prevention Act of 2014 (H.R. 5771) into law, following its passage through Congress on Tuesday. Among other things, the act will provide a one-year retroactive extension...more

Tax Law Alert: The Tax Increase Prevention Act of 2014 Extends Expired or Expiring Provisions

Congress this week passed the Tax Increase Prevention Act of 2014 (the Act), which is expected to be signed by President Obama at any time. The Act renews or extends a number of expired or expiring provisions. Some of the...more

Congress Passes One-Year Extension of Business and Individual Tax Provisions

On December 16, 2014, the Senate voted 76-16 to pass H.R. 5771, the Tax Increase Prevention Act of 2014 (“TIPA”), which was passed by the House by a vote of 378-46 on December 3, 2014. TIPA would extend over fifty (50)...more

Southeast State & Local Tax: Important Developments - November/December 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast....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

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

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

Year-end Uncertainty Highlights Need for Tax Reform

As we approach year-end, we again find ourselves in an all-too-familiar and unsettling situation — one in which we do not know the rules of the game we are about to play. Many popular tax planning opportunities, like the R&D...more

Focus on Tax Strategies & Developments - November 2014

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders  [Video]

Nov. 3, 2014 -- Allen Appel, Professor at New York Law School and Director of the International Tax Program, talks with Lee Pacchia about corporate inversions....more

IRS Proposes To Eliminate ‘Confusing’ 36-Month Non-Payment Testing Period for Cancellation of Debt

The Internal Revenue Service recently proposed very well-received regulations under Section 6050P of the Internal Revenue Code (the Code) that would eliminate the requirement for financial entities to treat debt as canceled...more

Southeast State & Local Tax: Important Developments - September/October 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA - INDIVIDUAL INCOME TAX...more

Recent New Jersey Tax Court Decision Creates Income Tax Refund Opportunity

In the recently decided case PPL Electric Utilities Corp. v. Director, Drinker Biddle was successful in convincing the New Jersey Tax Court that neither the Pennsylvania capital stock tax nor the gross receipts tax are...more

New Treasury Regulations Target Corporate Inversions

Last week, the Internal Revenue Service and Treasury Department announced a number of new regulations intended to make it more difficult to qualify for tax advantages associated with inversion transactions and reduce certain...more

Can Taxpayers Find an Advantage in Vodafone Nowhere Income Argument?

It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900...more

Philadelphia School Income Tax Imposed on Undistributed S Corporation Income

The City of Philadelphia Revenue Department (“City”) is assessing the School Income Tax (“SIT”) on the entire share of a resident S Corporation shareholder’s income, whether or not distributed. The assessments reach back to...more

Skandia: Intra-Company Supplies Treated as Taxable Transactions for VAT Purposes by the Court of Justice of the European Union

On 17 September 2104, the Court of Justice of the European Union (the “CJEU”) gave its preliminary ruling in the case of Skandia America Corporation USA, Sweden Branch v Skatterverket (C-7/13) (“Skandia”). The decision of...more

International Tax News - September 2014

BASE EROSION PROFIT SHIFTING PROJECT RECOMMENDATIONS TO COMBAT TAX AVOIDANCE BY MULTINATIONALS - At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering...more

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