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Corporate Taxes Management Fees

BCLP

A Capital Blow for Deducting Management Expenses

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The Supreme Court confirmed in Centrica Overseas Holdings Ltd v HMRC that the tests for trading and management expenses of a capital nature are the same. The decision also confirms that once a company has decided in principle...more

Rivkin Radler LLP

Constructive Dividends and The Closely Held C Corporation

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Withdrawing Value- Any tax adviser who has represented closely held businesses and their owners long enough realizes there are certain recurring themes that transcend the otherwise unique characteristics of the industry of...more

Farrell Fritz, P.C.

Corporate Tax Hike On The Horizon: Using Reasonable Compensation To Withdraw Value

Farrell Fritz, P.C. on

Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...more

Bennett Jones LLP

New GST/HST Rules Enacted for Fund Management Fee Arrangements

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On December 13, 2018, legislation was passed implementing amendments to the Excise Tax Act (Canada) (the “ETA”) first announced in September 2017 affecting GST/HST on management and administrative services provided to private...more

Akin Gump Strauss Hauer & Feld LLP

Carried Interest and Other Tax Reform Highlights for Investment Funds and Asset Managers

• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more

Troutman Pepper

ALJ Forces Combination of Hedge Fund Group in New York City - Tax Update Volume 2017, Issue 4

Troutman Pepper on

On April 27, the New York City Tax Appeals Tribunal issued a decision requiring the related members of a hedge fund group to file a combined return for New York City tax purposes. However, the administrative law judge (ALJ)...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 8

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, Issue 7 - July 2015

In This Issue: - Important Changes at NYS and NYC Tax Agencies - Court of Appeals Upholds Constitutionality of Taxing Nonresidents on Gain from S Corporation Stock Sale in Two Separate Decisions - NYC Tribunal...more

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