Excise Tax

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Aircraft Transaction Basics - A Business Development Opportunity

This paper will describe the basics of aircraft transactions, including aircraft sale, purchase and ownership issues and how current aviation practitioners can expand their practice area to include aircraft transactions, pull...more

Choice of Forum in Federal Excise Tax Refund Cases

To challenge an administrative determination and assessment of federal excise tax, taxpayers in refund cases have a choice of two different federal courts to bring an action: the U.S. federal district court and the U.S....more

Tax Reform Proposal Takes Aim at Executive Compensation

On February 26, 2014, U.S. Congressman Dave Camp released a comprehensive tax reform proposal that includes several provisions intended to limit or restrict executive compensation. Congressman Camp’s proposal includes the...more

March and April 2014 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more

House Ways and Means Chair Camp Releases Comprehensive Tax Reform Proposal

As expected, House Ways and Means Committee Chair Dave Camp (R-Mich.) released his long-awaited tax reform discussion draft on Wednesday, February 26, in which he seeks to lower the individual and corporate tax rates as well...more

Spotlight on Tennessee: Department of Revenue Addresses Manufacturer's Sourcing of Drop Shipment Receipts

For Tennessee excise and franchise tax purposes, a taxpayer that has business activities taxable both inside and outside this state must apportion its business net earnings and net worth using a three-factor apportionment...more

No U.S. Excise Taxes On Foreign Retrocessions

Foreign retrocession insurance transactions are beyond the reach of IRS excise taxes based on the plain language of 26 U.S.C. § 4371(3), which aims to tax insurance transactions involving policies issued by foreign insurers...more

Tax Court Interprets “Ownership” For Purposes Of GST/HST New Housing Rebate

In Rochefort v. The Queen (2014 TCC 34), the Tax Court of Canada provided clarity on the definition of “ownership” for the purposes of the GST/HST New Housing Rebate. Justice Campbell Miller held that “ownership” in...more

District court finds that insurance premium excise tax does not apply to retrocession transactions

On February 5, 2014, the US District Court for the District of Columbia held that the federal excise tax ("the FET") on insurance and reinsurance premiums does not apply to retrocession insurance transactions. Under a plain...more

Victory for the Taxpayer in Validus: District Court Holds that Federal Excise Tax Does Not Apply to Retrocessions

On February 5, the U.S. District Court for the District of Columbia issued its opinion in Validus Reinsurance, Ltd. v. United States, which is the first case to involve a challenge to the IRS’s position on the “cascading”...more

Brindisi Tax Academy -- 2013 Year-End Tax Update

I. A Look Back At 2013 Tax Matters, “Gangnam Style” - A. Some Random Observations. - 1. When we penned last year’s Update for you, dear reader, this fair country of ours stood six feet from the edge of the “...more

2014 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more

“Greenmail” Makes a Comeback

The much-maligned 1980s tactic of “greenmail” appears to have made a comeback in 2013. “Greenmail” has generally been defined as the practice of purchasing enough shares in a company to threaten a takeover, and then using...more

European Commission Investigates Exemption from Renewable Energy Surcharge for Energy-Intensive Companies in Germany

The European Commission today opened a State aid investigation into the German Renewable Energy Source Act (the EEG), claiming that the EEG may have given unlawful advantages to energy-intensive companies in Germany. These...more

PA Sales Tax Ruling Clarifies Computation of Taxable Purchase Price for Tractor Trailers

The Pennsylvania Department of Revenue has ruled that the Federal excise tax imposed by Section 4051 of the Internal Revenue Code on certain commercial vehicles is not to be included in the taxable purchase price for sales...more

Spotlight on Tennessee: DOR Clarifies Franchise and Excise Tax Classification of SMLLCs and Series LLCs

In November, the Tennessee Department of Revenue (Department) issued two notices to help clarify Franchise and Excise Tax classification of single member LLCs (SMLLCs) and series LLCs. ...more

December 2013 and January 2014 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more

November and December Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more

Tax Talk -- Volume 6, No. 3 -- October 2013

In This Issue: A Primer on the Medical Device Excise Tax; FATCA Registration Begins; In re Downey Financial Corp. (U.S. Bankr. Court Dist. of Delaware 10/8/2013); In re NetBank (11th Cir. 9/10/2013); and In re...more

California Reduces Rate of Section 409A State Excise Tax

In a positive development for employees, California recently reduced its excise tax rate for failures to comply with the California analog to Section 409A of the Internal Revenue Code of 1986, as amended (“Section 409A”)....more

Massachusetts Tax Developments - A Reed Smith Quarterly Update (3rd Quarter 2013)

Welcome to the Reed Smith Massachusetts State Tax Quarterly Update for the 3rd Quarter of 2013. This update includes coverage of the repeal of the short-lived software services tax and pending litigation on other...more

Massachusetts Rules Against Taxpayer on Treatment of Intercompany Debt—Again

In what is becoming a trend, the Massachusetts Appellate Tax Board (the "ATB") has issued yet another decision denying true debt treatment for an intercompany obligation. In National Grid Holdings, the ATB upheld assessments...more

Sutherland SALT Shaker: August 2013 Digest

In this issue: - No Expressions of Goodwill from Arizona Department of Revenue - California Court of Appeal: ITFA Doesn’t Make the CUT - Round We Go: Indiana Denies Taxpayer’s Intercompany “Residual...more

Waiving Rights Of Objection And Appeal: SCC Declines To Hear The Taxpayer’s Appeal In Taylor v. The Queen

On August 15, 2013, the Supreme Court of Canada dismissed the application for leave to appeal in Terry E.Taylor v. Her Majesty the Queen (2012 FCA 148). In Taylor, the issue was whether a signed settlement agreement...more

The Importance Of A Notice Of Objection: Salisbury v. The Queen

In Salisbury House of Canada Ltd. et al. v. The Queen (2013 TCC 236), the Tax Court of Canada reiterated the importance of the statutory preconditions that must be met before a taxpayer may appeal to the Court. ...more

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