Effective January 1, 2013, the American Taxpayer Relief Act of 2012 (“ATRA”) was enacted into law, finally settling years of debate over the fate of the Bush era tax cuts. On the same day, the 3.8% Medicare Tax on net...more
In Brianne Gwartz v. The Queen, 2013 TCC 86, the Crown attempted to utilize the GAAR to recharacterize as dividends certain capital gains which had been realized by a family trust and allocated to the minor-aged taxpayers in...more
Background — We have analyzed the terms of venture financings for Israeli and Israeli-related technology companies that reported raising money during 2012. Our survey does not include financing rounds of less than US...more
In this issue: - California Court of Appeal: No Man May Profit From His Own Wrongdoing in a Court of Justice - The (True) Object of My Affection: A Nontaxable Stock Screening Service - Alternate Universe...more
Common Features of Preferred Share Investments in Startups - Venture capitalists and other early stage investors typically invest in startups and emerging growth companies through preferred shares (normally with...more
As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more
On April 10, the Obama Administration released its fiscal year 2014 budget (FY 2014 Budget). Of note, the FY 2014 Budget includes a number of tax proposals that target insurance companies or that otherwise would have a direct...more
Single compliance mark commences - The single regulatory compliance mark (RCM) scheme began on 1 March 2013. This begins a 3 year transitional period with compulsory A-tick and C-tick marks being phased out by 1 March...more
Introduction - Cyprus has been in the spotlight recently due to the negotiations with what has become known as the troika (the International Monetary Fund, the European Central Bank and the European Commission)...more
Reform of taxation of free floating dividends for corporate income tax purposes The German Parliament (Bundestag) and the German Federal Council (Bundesrat) reached an agreement regarding the taxation of free floating...more
To insulate the ultimate individual owners from U.S. estate taxes, nonresident aliens often hold U.S. real property in a U.S. corporation, which corporation is owned by a foreign corporation. The foreign corporation is owned...more
According to Black’s Law Dictionary, a “gift” is a “voluntary transfer of property to another made gratuitously and without consideration”. Thus, it would seem that a gift could not be a sale. The California Corporations...more
On January 24, 2013, the United States and Japan signed a proposed protocol to amend the existing tax treaty between the two countries, which was entered into in 2003. The amendments, which will take effect when ratified by...more
After much contention,Congress passed the American Taxpayer Relief Act of 2012, and President Obama signed the legislation on January 2, 2013. The Act avoids automatic sunset provisions that were scheduled to take effect...more
With the American Taxpayer Relief Act of 2012 (the “ATRA ”) passed and the fiscal cliff safely averted, the time has come to turn your attention to your estate plan. What Did the ATRA Accomplish? The fiscal cliff...more
For all the public discussion in 2012 of the need for a significant reformation and restructuring of the Internal Revenue Code, the income tax provisions of the American Taxpayer Relief Act of 2012 (the 2012 Act) are at their...more
Now that a deal averting the fiscal cliff has finally been reached, many of the tax and planning issues that have been mired in uncertainty for the past two years (and even longer in some cases) may be resolved. Numerous tax...more
On January 2, President Barack Obama signed into law the American Taxpayer Relief Act of 2012, H.R. 8 (ATRA), preserving many of the key tax provisions passed during the George W. Bush presidency, which were scheduled to...more
2012 Tax Act - The American Taxpayer Relief Act of 2012 (the “Act”) was signed into law on January 1, 2013 to avert the tax law changes that were one part of the “fiscal cliff” facing our country’s economy (the other...more
Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more
On Jan. 2, 2013, President Obama signed the “American Taxpayer Relief Act of 2012” (the “Act”) which was passed by the House and Senate the previous day to avoid the so-called “fiscal cliff.” The Act prevents many of the tax...more
The Board of Governors of the Federal Reserve System (“Board”) has devoted some time to considering how to address the potential threat to the financial stability of the United States posed by a foreign bank with banking...more
Summary - President Obama on January 2, 2013 signed into law the American Taxpayer Relief Act of 2012 (the “Act”). The Act extends certain tax rates, tax credits, and other provisions previously enacted by other tax...more
On January 1, 2013, Congress averted the fiscal cliff with the passage of the American Taxpayer Relief Act of 2012 (Act), which was enacted when President Obama signed the Act on January 2, 2013. The Act provides a welcome...more
On January 1, 2013, the Senate and House of Representatives passed the American Taxpayer Relief Act of 2012 (“ATRA”), signed into law by President Obama on January 2. ATRA averts the “fiscal cliff” by making permanent the...more
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