News & Analysis as of

Corporate Taxes

Despite Clash Over Tax Cuts, Governor Dayton Signs Bill Enacting Important Income Tax Changes for Minnesota Residents and...

by Dorsey & Whitney LLP on

On May 30, 2017, Governor Dayton signed into law Minnesota’s omnibus tax bill (HF 1), which contains significant income tax changes of interest to both residents and nonresidents of Minnesota. Initially, Governor Dayton...more

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

Virginia Imposes Fees for Requests for Certain Actions by the Departments

by Williams Mullen on

Starting July 1, 2017, taxpayers that request an “Offer in Compromise with respect to doubtful collectability under Sec. 58.1-15, a Ruling Letter from the Commissioner under Sec. 58.1-203, a local tax advisory opinion under...more

IRS Can Pursue “Responsible Persons” for Unpaid Trust Fund Taxes and Automatic Stay Cannot Be Used to Enjoin Collection Against...

The Puerto Rico Bankruptcy Court followed the Third Circuit in holding that the Anti-Injunction Act, which prohibits suits to restrain the assessment or collection of any tax, is not superseded by section 105(a) of the...more

IRS Announces Tax Audit Targets

Over the past several years, IRS has reduced the number of its tax auditors by about 25 percent – from just over 12,000 tax auditors in 2011 to about 9,000 tax auditors in 2015. This staffing reduction has forced IRS to focus...more

Tax incentives in Puerto Rico: a quick introduction

by DLA Piper on

To promote, attract and develop key industries, sectors and activities, Puerto Rico offers a spectrum of economic incentives, among them low fixed income tax rates, partial and/or total tax exemptions, income tax credits and...more

European Court of Justice rules Belgian fairness tax in breach of the Parent Subsidiary Directive

by DLA Piper on

The European Court of Justice (ECJ) has ruled that the Belgian fairness tax violates the Parent-Subsidiary Directive in certain specific circumstances. This decision may be the latest step leading to the annulment of the tax,...more

Tax Reform 2017 - Will it Ever Come?

by Dickinson Wright on

For tax attorneys, tax reform is always a hot topic. President Trump was elected with GOP majorities in both chambers of Congress, which would normally make the forecast for tax reform actually being enacted favorable. ...more

Eagerly Awaited "Market-Based Sourcing" Guidance Issued by Connecticut Department of Revenue Services

by Shipman & Goodwin LLP on

On April 17, 2017, the Connecticut Department of Revenue Services (“Department”) released eagerly awaited market-based sourcing guidance. The guidance will have an impact of virtually all companies (regardless of form) doing...more

More than 60 countries sign OECD multilateral convention to counter base erosion and profit shifting

by DLA Piper on

This week's signing ceremony for the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS marks a new and important milestone in the international tax agenda to tackle perceived abusive...more

US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

by Hogan Lovells on

Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from...more

Buying a company in business rescue that has assessed tax losses

by Hogan Lovells on

Companies in business rescue often have built-up assessed losses for tax purposes. Competitors wishing to take over the business of the company in business rescue would often view such assessed loss as a valuable asset, in...more

Funds Talk: June 2017 - The IRS Resumes Issuing Private Letter Rulings on ‘Leveraged’ and ‘North-South’ Spinoffs

The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its “no-rule” list since 2013. In a...more

Circular on Pilot Tax Policies for Venture Capital Firms and Individual Angel Investors

In order to promote the sustainable and healthy development of venture capital investment, the Ministry of Finance and the State Administration of Taxation have jointly promulgated the Circular on Pilot Tax Policies for...more

Law à la Mode: Special Edition - INTA 2017

by DLA Piper on

The Belgian editorial team is delighted to bring you this special edition of Law a` la Mode, marking the 139th INTA Annual Meeting in Barcelona. Just some of the focuses for this special edition include the dangers of...more

California FTB Provides Guidance on Certain Section 382 Calculations - Tax Update Volume 2017, Issue 3

by Pepper Hamilton LLP on

California requires taxpayers that have income within and outside the state to "apportion" their overall income between the two categories based upon certain factors and rules for determining their California tax liability....more

Update on US Federal Tax Reform Proposals and Their Effect on the Renewable Energy Industry

by Shearman & Sterling LLP on

While tax reform has been a stated focus of the Trump administration and Congress, details remain elusive. The administration has recently reaffirmed its desire to enact comprehensive corporate and individual tax reform, but...more

Tax Reform Pushing Ahead

Despite the political controversy swirling around the firing of James Comey and the appointment of a special prosecutor, the White House and Republicans are determined to push forward with tax reform. Later this week,...more

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

German Constitutional Court Declares Parts of Provisions Regarding Forfeiture of Tax Losses and Loss Carry Forwards...

by Shearman & Sterling LLP on

The German Constitutional Court held in its decision dated 29 March 2017 (published on 12 May 2017) Section 8c sentence 1 German Corporate Income Tax Act (KStG) (introduced in 2008 and replaced by the identical provision of...more

Federal Tax Reform and the Oklahoma Income Tax

by GableGotwals on

Tax reform is being proposed in Congress and by President Trump to make major changes to the federal income tax imposed under the Internal Revenue Code. Oklahoma imposes a state income tax on individuals, corporations, and...more

Trump’s Tax Reform Plan – When the Dessert Pays for Dinner

by Alston & Bird on

Doubling down on his promise to achieve monumental tax reform, President Trump on April 26 issued a tax reform plan outlining his Administration’s broad aims. Once again, he has made it clear that large-scale tax reform is a...more

Federal Tax Reform Legislation in 2017: Comments by Attorney Morris N. Robinson

Attorney Morris N. Robinson, the Managing Director of M. Robinson Tax Law in Boston, recently published an op-ed titled: Viewpoint: A 15 percent tax rate on business would maximize economic growth....more

Trump Administration Proposes Significant Tax Overhaul

by Baker Donelson on

On April 26, Treasury Secretary Steven Mnuchin and Gary Cohn, director of the National Economic Council, presented the Trump Administration's tax reform proposal to the media. The proposal consisted of a one-page outline that...more

Development of court practice of determining the starting date for payment of property tax on a fixed asset that is ready for...

by Dentons on

On 28 April 2017 the Commercial Court of St. Petersburg and Leningrad Region rendered a decision in case No. ?56-87465/2016 (the “Decision”) under the claim of Penobeton-Pikalevo LLC (the “Company”). The case considered the...more

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