Income Taxes

Employers With Share Option Schemes Take Note…

by Richard Cook, James Ross | McDermott Will & Emery on 5/23/2013

A recent decision of the United Kingdom’s First Tier (Tax) Tribunal has provided a timely reminder of the importance for employers of notifying their employees of the requirement to promptly reimburse the employer for income...more

N.Y. ALJ Holds Taxpayer’s Motives for Acquiring Stock and How Stock Is Used Irrelevant in Determining Investment Capital

by Lindsay LaCava, Arthur R. Rosen | McDermott Will & Emery on 5/22/2013

A New York administrative law judge recently held in Matter of C.V. Starr & Co., Inc. that income received by a taxpayer from its ownership of common stock was investment income. In so holding, the ALJ addressed an important...more

Estate Planning Alert: New Civil Marriage Law Could Increase Income Tax Costs, May Offer Estate Tax Benefits

by Michelle Rehbein, Shane Swanson | Leonard, Street and Deinard on 5/22/2013

On May 14, 2013, Governor Dayton signed a bill modifying Minnesota Statutes Sections 517 and 518. The bill enacts changes in Minnesota's marriage law, effective August 1, 2013....more

New Mexico 2013 Tax Legislation Update

by Timothy R. Van Valen | Brownstein Hyatt Farber Schreck on 5/22/2013

The recently concluded 2013 regular session of the New Mexico Legislature resulted in legislation enacting several significant changes to New Mexico’s tax programs, the majority of which are business friendly. Most of the...more

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

On February 1, 2013, the U.S. District Court for the Eastern District of Wisconsin sentenced Arvind Ahuja, a Milwaukee neurosurgeon, to serve three years of probation and to pay a fine of $350,000 following his conviction by...more

HM Revenue & Customs Consultation Document Poses Significant Tax Challenges for Investment Management LLPs

by David Gubbay, Daniel Hawthorne, Mark Stapleton | Dechert LLP on 5/21/2013

On 20th May, HMRC published a consultation document which proposes major changes to the taxation of partnerships in the UK. The consultation is particularly relevant to investment management LLPs – and especially to those...more

High Net Worth Family Tax Report, Vol. 8, No. 2 -- May 2013

by Loeb & Loeb LLP on 5/18/2013

President’s fiscal year 2014 budget contains numerous tax provisions - President Barack Obama released his proposed budget for the government’s fiscal year 2014 on April 10, 2013, and, not surprisingly, the budget...more

Congress Reinstates Income Tax Advantages for Conservation Easements

by Womble Carlyle Sandridge & Rice, PLLC on 5/17/2013

Executive Summary: Congress has temporarily reinstated certain income tax advantages for donations of conservation easements. These advantageous provisions are scheduled to expire at the end of 2013....more

California Court Finds Securitization Entities Subject to California Income Tax

by Marty Dakessian, Mike Shaikh, Kyle O. Sollie | Reed Smith on 5/13/2013

A California Superior Court has issued a decision with significant impact on financial services. In the case, Harley-Davidson, Inc. v. Franchise Tax Board, San Diego Superior Court Judge Joel Pressman held that...more

Federal Court Of Appeal Strikes Out A Pleading Alleging That Expenses Are Non-Deductible In Light Of “Egregious And Repulsive”...

by David Spiro | Dentons on 5/13/2013

In a ruling handed down May 6, 2013, the Federal Court of Appeal ordered that portions of a Crown pleading be struck out for suggesting that a deduction may be disallowed on the basis that the conduct of the taxpayer in...more

Editorial: Expatriating From U.S. To Puerto Rico May Make Sense For Some

by Jeffrey L. Rubinger | Bilzin Sumberg Baena Price & Axelrod LLP on 5/13/2013

The United States is one of only two countries in the world that taxes its citizens and residents on their worldwide income. Therefore, a U.S. taxpayer who earns only foreign-source income will be subject to U.S. federal...more

Tales from the Crypt -- Post-Mortem Planning Using Private Placement Insurance Products

by Gerald Nowotny on 5/9/2013

Overview - This article discusses the use of private placement products - private placement deferred variable annuities (PPVA) and private placement life insurance (PPLI)- in post mortem income tax and transfer tax...more

TPC’s Analysis Of President Obama’s 2014 Budget

by Bruce Rawls | Burr & Forman on 5/9/2013

The Tax Policy Center (the “TPC“) has published its analysis of the tax proposals included in President Obama’s 2014 budget. The analysis finds that President Obama’s proposals would have the intended effect of...more

Illinois Tax Developments - A Reed Smith Quarterly Update (1st Quarter 2013)

by Adam P. Beckerink, Denise Obrochta, Jennifer C. Waryjas, Michael Wynne | Reed Smith on 5/8/2013

Welcome to the first of a new series of quarterly updates from Reed Smith on state tax developments in Illinois. Every three months we will be giving you updates on the key cases and administrative releases, as well as...more

OVDI Pre-Clearance Letters And Their Revocability

by Charles (Chuck) Rubin on 5/8/2013

The first step a taxpayer with undisclosed or unreported offshore accounts or assets undertakes in seeking to enter the Offshore Voluntary Disclosure Initiative (OVDI) is to apply for pre-clearance from the IRS Criminal...more

Employment Law Blog: The Price of Generosity - PTO Donation Policies

by Jo Ellen Whitney | Davis Brown Law Firm on 5/8/2013

At Davis Brown's recent Employment Law Seminar, a hot topic was the structure and utilization of Paid Time Off and leave donation programs. Iowans tend to be generous givers. We step forward, we raise the barn, bake a pie,...more

Integrating Foreign Currency Hedges With Respect To Stock Purchase And Sale Agreements

by Steven Bortnick | Pepper Hamilton LLP on 5/7/2013

Investment funds that invest globally must deal with volatility in the currency in which they agree to invest. Investment funds entering into obligations to purchase stock in a currency other than the primary currency of the...more

Small and Mid-Size Companies: Beware of Increased Cybersecurity Threats of Sensitive Tax Information

by Helen Christakos, Brendan Lund | Carr, McClellan, Ingersoll, Thompson & Horn -... on 5/3/2013

Small and mid-size companies electronically transmit an increased amount of sensitive financial information via the Internet to comply with tax compliance obligations....more

Sweeping Maine Tax Reform Proposal Announced

by Sarah Beard, Jonathan Block, Kris Eimicke | Pierce Atwood LLP on 5/3/2013

A bipartisan group of 11 legislators have proposed an overhaul of Maine’s tax system, including major changes to the individual and corporate income tax, property tax, sales tax, and estate tax. ...more

Sutherland SALT Shaker: April 2013 Digest

by Mary Alexander, Andrew Appleby, Zachary Atkins, Madison Barnett, Todd Betor, Scott Booth, Christopher Chang, Timothy Gustafson, Saabir Kapoor, Jessica Kerner, Shane Lord, Pilar Mata, more +Suzanne Palms, Kathryn Pittman, David Pope, Maria Todorova, Jack Trachtenberg, Prentiss Willson | Sutherland Asbill & Brennan LLP on 5/1/2013

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

IRS Chasing Down ‘Quiet Disclosures’

by Charles (Chuck) Rubin on 4/30/2013

In a recent report, the General Accounting Office (GAO) encourages the IRS to do more to uncover and pursue taxpayers who made quiet disclosures in regard to their non-U.S. accounts....more

Taxation Of Computer Software Sales: Ordinary Income, Capital Gain, Or Both?

by David Blum | Levenfeld Pearlstein on 4/29/2013

The taxation of computer software is complex, confusing, and in some circumstances, uncertain; although self-created computer software is routinely sold today, especially with the significant increase in the number of...more

Dodgeball - The Tax Version

by Gerald Nowotny on 4/29/2013

Since the passage of The American Taxpayer Relief Act of 2012 and the submission of the President's federal budget proposal for 2014, it is clear that high net worth and high income taxpayers continue to be under attack....more

International Business, Tax, Estate and Asset Preservation Planning - April 2013: Expatriation Tax Rules: Green Card Holders...

by Stephen A. Malley, APC on 4/26/2013

The curiously titled "Heroes Earnings Assistance and Relief Tax Act of 2008" became law 17 June 2008. This was the third major revision of expatriation rules in 12 years. While the Act provides laudable benefits to armed...more

U.S. Department of the Treasury Announces $3.5 Billion in Federal New Markets Tax Credit Allocation Authority

by Amelia Frankel, Jarrod Sharp, Jennifer Simmons | Thompson Coburn LLP on 4/26/2013

Yesterday the U.S. Department of the Treasury’s Community Development Financial Institutions Fund (the “CDFI Fund”) announced the award of $3.5 billion in Federal New Markets Tax Credit (NMTC) allocation authority through its...more

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