Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders
What Questions CEOs and Board Members Should Be Asking Themselves About Tax Inversions
Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal
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
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
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
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
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
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
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
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
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
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.
INDIVIDUAL INCOME TAX...more
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
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
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
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
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
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
In Devon Canada Corporation v. The Queen the issue is whether the taxpayer (“Devon”) may deduct $20,884,041 paid to cancel issued stock options. After the close of pleadings, the Crown brought a procedural motion relating to...more
It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more
Most of the time the state-law classification of an entity and its federal income tax classification match. A corporation will be taxed as a corporation and a partnership will not be taxed, instead merely filing an...more
We are delighted to provide you the third edition of our “Inbound acquisitions at a glance” brochure.
In today’s increasingly complex business environment, awareness of the tax environment in relevant jurisdictions is...more
State income tax laws generally build on federal tax law. The typical pattern is to begin the calculation of state taxable income with federal taxable income and then to modify it by adding or subtracting items where state...more
There may be significant legislative and regulatory activity over the next few months as the US Congress and the Obama Administration continue to grapple with corporate tax inversions. While it remains unlikely that...more
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes.
Do you have responsibility, whether direct or dotted line, for the tax function in your...more
Earlier this year, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen (2013 TCC 404) (see Federal Court of Appeal File Nos. A-48-14 and A-49-14).
In an appeal by HMRC against a decision of the First-tier Tribunal ("FTT"), the Upper Tribunal (Tax and Chancery Chamber) ("UT") decided that a penalty imposed on McLaren Racing Limited ("McLaren") in respect of a breach of...more
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