News & Analysis as of

Income Taxes

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more

New Seattle Income Tax: Answers to Your FAQs

by Perkins Coie on

The City of Seattle adopted Ordinance 125339 on July 14, 2017, which imposes an income tax on Seattle residents and certain irrevocable trusts. The Seattle income tax is imposed at a rate of 2.25% of a resident taxpayer’s...more

Golly Gee—the U.S. Tax Court Ruled That the Cost of a Taxpayer's Microsoft Xbox 360 and a Nintendo Wii Used by His Children Did...

by Garvey Schubert Barer on

In 2015, the U.S. Tax Court issued its ruling in the case of David W. Laudon v. Commissioner, TC Summary Option 2015-54 (2015). The case may not raise or even resolve any novel tax issues, but it reminds us of what is...more

Recent U.S. Tax Court Case Reverses Long Held IRS Position Regarding Taxation of Sales of Partnership Interests by Foreign...

by Locke Lord LLP on

Following the inauguration of the new administration in January 2017, many investors were anticipating the passage of a transformative tax reform bill at some point in 2017. Although legislative tax reform is seemingly...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

Georgia Senate Special Tax Exemption Study Committee Holds First Meeting 

During the 2017 Legislative Session, Senate Resolution 222 created the Senate Special Tax Exemption Study Committee, which was tasked with examining the “costs and benefits” of all exemptions for Georgia sales and use taxes...more

Disposition of U.S. Partnership Interest Will Not Result in Effectively Connected Income to Foreign Partner

by Charles (Chuck) Rubin on

What happens when a foreign individual or corporation sells an interest in a partnership that is engaged in a U.S. trade or business? The Internal Revenue Code does not directly answer this question - the answer lies at the...more

Tax impact of the repeal of the foreign employment income exemption on South African professionals

by Hogan Lovells on

The Taxation Laws Amendment Bill 2017 (2017 TLAB) was published for public comment on 19 July 2017. One of the changes proposed is the repeal of the so-called foreign employment income exemption, contained in section...more

Draft tax legislation for 2017 released

by Hogan Lovells on

Following the 2017 Budget presented before Parliament on 22 February 2017, the draft tax legislation for the specific tax proposals was released on 19 July 2017 for comment. Comments should be made by 18 August 2017. ...more

UK: The Biggest Shake Up of Employment Law in a Generation?

by Littler on

On July 11, 2017, the UK government published the Review of Modern Working Practices. The report was issued by Matthew Taylor, chief executive of the Royal Society of Arts and a former policy chief to Tony Blair. Current...more

Newsflash: Tax Court Reverses IRS Revenue Ruling

by Dechert LLP on

A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more

Alert: New Tax Court Decision Opens the Door for Tax Planning for Non-US Investors into US LLCs

by Cooley LLP on

On July 13, 2017, the US Tax Court issued a decision which may provide non-US investors more flexibility and potentially better tax outcomes with respect to structuring their investments into US LLCs and partnerships....more

Q&A with Sheppard F. Miers: Federal tax reform could affect state tax determinations

by GableGotwals on

Q: Would tax reform at the federal level affect the taxes we pay at the state level? A: Oklahoma state income tax generally conforms to the federal income tax imposed under the Internal Revenue Code. In general, income and...more

Updated Health Care Reform Legislation Comparison Chart

The chart below compares key provisions of the Affordable Care Act (ACA), the American Health Care Act (AHCA) and the Better Care Reconciliation Act (BCRA). This chart is current as of July 13, 2017, and as of that date,...more

Texas Data Thieves Sentenced To Prison For $1.8 Million Fraud Scheme

by King & Spalding on

On June 30, 2017, the U.S. Attorney’s Office for the Southern District of Texas announced the sentencing of two men convicted of conspiring to claim up to $1.8 million in fraudulent income tax refunds from the Internal...more

BEWARE! Impact of New Tax Rules on Your Family Limited Partnership

by Strasburger & Price, LLP on

Family limited partnerships (“FLPs”) are a common estate planning technique. They permit centralized asset management, provide liability protection, and create a mechanism by which one generation can transfer wealth to the...more

Update to Guide on U.S. Taxation of Nonresident Aliens

by Charles (Chuck) Rubin on

I first wrote a simplified guide to U.S. taxation of nonresident aliens before the Internet and emails. The first few editions were printed and mailed out to persons on our firm's mailing list. Eventually, I circulated it by...more

Tax Changes Implemented As Part of Revenue Package Supporting Illinois Budget

by McDermott Will & Emery on

July 6, 2017, after months of wrangling and a marathon 4th of July weekend session, the Illinois House of Representatives voted to override Governor Bruce Rauner’s veto of Senate Bill (SB) 9, the revenue bill supporting the...more

Funds Talk: July 2017 - Structuring Considerations for Direct Lending Funds

Kramer Levin’s Alternative Investment Management practice recently hosted “Structuring Considerations for Direct Lending Funds,” a seminar designed to assist those fund managers who form investment vehicles to lend to small...more

Charitable Giving Strategies

by Bowditch & Dewey on

If you have been looking for ways to give back this summer, you might want to try something different. The majority of people donate to charitable organizations through gifts of cash, but this may not be the most...more

Tax Legislation Enacted During the Regular Session of the 2017 North Carolina General Assembly

by Smith Anderson on

A previous Tax Alert (June 20, 2017) summarized the tax provisions in the North Carolina 2017 budget bill (the Appropriations Act of 2017) as passed by the General Assembly. The Governor later vetoed the budget bill, but the...more

Development of court practice on tax disputes over charging personal income tax on amounts paid to employees by agreement at...

by Dentons on

On 16 June 2017 the RF Supreme Court rendered a ruling in case No. ?42-7562/2015. In this case the court considered a dispute between Murmansk Trawl Fleet PJSC (hereinafter MTF) and the Federal Tax Service Interdistrict...more

What Could President Trump’s Proposed Tax Reforms Mean for the Municipal Bond Market?

by Cozen O'Connor on

While there are many unknowns and uncertainties surrounding President Trump’s proposed tax reforms, below is a brief review of three of his proposals that could have an impact on the municipal bond market. ...more

2017 Oklahoma Tax and Fee Legislation

by GableGotwals on

The following are some of the changes in Oklahoma law on state taxation and fees enacted by the Oklahoma Legislature in 2017. Income Tax - Oklahoma Standard Deduction Decoupled from Federal Standard Deduction. For...more

Tax Savings in the United States Virgin Islands – the Basics

by Garvey Schubert Barer on

When many people think of the United States Virgin Islands (“USVI”), they think of beautiful beaches on secluded islands. This is certainly correct, but many people do not know that the USVI is also home to some of the most...more

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