News & Analysis as of

Federal Taxes

Federal Tax Liens In Foreclosure Proceedings

by Ward and Smith, P.A. on

Henkel v. Triangle Homes is a North Carolina Court of Appeals case with dueling tax foreclosure proceedings involving the same property. One foreclosure proceeding was for unpaid municipal taxes and the other for unpaid...more

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

by Shearman & Sterling LLP on

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more

Taxpayer Wish List

by Alston & Bird on

Taxpayers who have concrete suggestions for changes in tax regulations that would make life easier for their business activities should take this opportunity to inform the Treasury of those needs. Several Treasury officials...more

CBO Releases Updated Cost Estimate of American Health Care Act of 2017

On May 24, 2017, the Congressional Budget Office (“CBO”) and the staff of the Joint Committee on Taxation (“JCT”) released a cost estimate for H.R. 1628, known as the American Health Care Act of 2017 (the “AHCA”). The CBO and...more

IRS Opposes Granting of Certiorari in Cases Addressing Definition of Return

by McDermott Will & Emery on

Two petitions for certiorari are pending before the Supreme Court of the United States, asking the Court to resolve the question of whether a tax return filed after an assessment by the Internal Revenue Service (IRS) is a...more

State and Federal Tax Law Developments Affect Same-Sex Couples and MA Residents with Out-of-State Real Estate

by Goodwin on

Recent changes in state and federal tax laws impact same-sex couples and any Massachusetts residents who own real estate in another state. Clients who may be affected by these changes should act soon to protect the...more

No Seriously, When is My Return Due?

It’s that time of the year again. Or maybe it isn’t. Effective for tax years beginning on or after December 31, 2015, the filing deadlines for many common federal tax returns have changed. As a result, taxpayers coming...more

South Carolina Court of Appeals, in Olds v. City of Goose Creek, Affirms Circuit Court Order Regarding Definition of Gross Income...

by McNair Law Firm, P.A. on

In Olds v. City of Goose Creek, 2016 S.C. App. LEXIS 147, the South Carolina Court of Appeals provides a thorough discussion of the application of the South Carolina business license tax to a taxpayer’s gross income. The...more

SALT Implications of Final Section 385 Debt-Equity Regulations

by McDermott Will & Emery on

The recently released final regulations under Internal Revenue Code Section 385, addressing the circumstances under which related company debt will be classified as equity for federal income tax purposes, will have a...more

What You Need to Know About IRS Outstanding Inactive Tax Receivables

by Foodman CPAs & Advisors on

Legislation enacted in 12/15 (FAST ACT – Fixing America’s Surface Transportation Act)) required IRS to utilize private debt collection agencies to collect inactive federal tax debts. Starting SPRING 2017, IRS will use private...more

Series LLCs in PA – Uncertainty Lessens

September 7, 2016 Publications Series LLCs are gaining traction across the country and, although Pennsylvania does not (yet?) permit the formation of Series LLCs, it has taken a major step in solidifying their acceptance...more

Sustainable Development Update - July 2016 #2

by Allen Matkins on

Sustainable Development Focus - Money flows into batteries for buildings, power grid - Fortune - Jul 11 - Over the past half decade, the solar market has boomed thanks to falling solar panel prices. Now the...more

South Carolina Legislative Tax Update: Governor Signs Bill Amending South Carolina Tax Law to Conform With the Internal Revenue...

by McNair Law Firm, P.A. on

Differences in federal and state tax laws can cause taxpayer headaches, and often lead to incorrect state tax filings. While South Carolina’s tax code continues to treat certain items differently than the Internal Revenue...more

Taxing LLC Options (It’s Complicated)

by Smith Anderson on

Options, warrants, convertible equity and convertible debt are all familiar tools of corporate finance. Taxing LLC Options covers the federal income taxation of non-compensatory options (NCOs) issued by partnerships and LLCs...more

A Short Summary of Qualified Small Business Stock Tax Benefits and Requirements

by DLA Piper on

Many startups, investors, clients and friends have recently asked about the tax benefits associated with having stock qualify as qualified small business stock (QSBS). This is an important issue that investors, founders and...more

MoFo Tax Talk - Volume 9, No. 1

by Morrison & Foerster LLP on

IRS Publishes Proposed section 305(c) Regulations - On April 12th, the IRS published proposed regulations under Section 305(c) that address the treatment of deemed dividends to holders of stock and rights to acquire...more

President Obama’s Administration Continues Its Quest to Limit the Ability to Defer Income Under IRC § 1031

by Garvey Schubert Barer on

As reported in my November 2014 blog post, President Obama’s administration wants to limit taxpayers’ ability to defer income under IRC § 1031. In response to former House Ways and Means Committee Chairman David Camp’s...more

[Event] Spring 2016 Tax Forum - May 12th, 8:00 am, Richmond, VA

by Williams Mullen on

Please join us for the Spring Tax Forum to be held at the Williams Mullen Center on Thursday, May 12, 2016. Topics Include: Contributions of Property to a Partnership: An Analysis of Section 704(c) Methods Part II:...more

Five Things Tribal Leaders Can Do in 2016 to Reduce Taxes on Tribal Members

by Holland & Knight LLP on

Contrary to popular misconception, individual members of Indian tribes do pay federal income taxes on their income, including on most of the income derived from Indian tribal or reservation sources. Some also pay state income...more

Congress Passes Passport Revocation Bill Aimed At Large Tax Debtors

On December 4, 2015, the President signed into law HR 22, which requires the IRS to notify the State Department of any U.S. citizen who owes more than $50,000 in federal taxes. The State Department is then directed to revoke...more

What About New York State’s Federal Tax Audits?

by Hodgson Russ LLP on

A noteworthy determination was issued earlier this month by one of the Division of Tax Appeals’ administrative law judges. Judge Bennett found in Matter of Chery that the Division of Taxation improperly denied the petitioning...more

Tax Code Amendments Facilitate Foreign Investment in REITs and U.S. Commercial Properties; Increase FIRPTA Withholding Tax Rate

by Locke Lord LLP on

On December 18, 2015, the United States Congress enacted the Protecting Americans from Tax Hikes Act of 2015 (the Act). Among other things, the Act permanently extends many “popular” tax provisions (e.g., the research and...more

New Legislation Makes Sweeping Changes Impacting All Partnerships

by Morgan Lewis on

All partnerships will be audited at the entity level unless they have 100 or fewer partners AND no partnerships as direct partners. The two-year budget plan passed by Congress on October 30, 2015, and expected to be...more

UK 2015 Summer Finance Bill Update: Proposed Taxation Changes for Carried Interest and DIMF

by Proskauer Rose LLP on

Further to our client alert in July this year, the UK Government recently proposed further changes to the UK taxation of carried interest and disguised investment management fees (DIMF). The UK Government proposed...more

IRS Issues Proposed Regulations to Accommodate Obergefell

On October 21, 2015, the IRS issued proposed regulations to clarify the treatment of same-sex spouses for federal tax purposes. By way of background, in 2013, the United States Supreme Court held in United States v. Windsor...more

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