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 -
News & Analysis as of

Changes To The Taxation Of Termination Payments

Summary - The government has published its response to feedback received on its proposals to simplify the taxation of termination payments, expected to come into force in April 2018. The following table sets out...more

Michigan Health Insurance Claims Assessment Act is Not Preempted by ERISA

The Sixth Circuit, has decided, on remand from the Supreme Court, that the Michigan Health Insurance Claims Assessment Act (Act) is not preempted by ERISA. The Act imposes a 1 percent tax on all paid claims by insurers or...more

Non-Dom Reforms Update – United Kingdom

Summary - Following the United Kingdom’s vote to leave the European Union on 23 June, and the change of Prime Minister and to the UK Government, there was significant uncertainty regarding what would happen to the...more

Pre-immigration and Non-U.S. Resident Planning

Foreign individuals who intend to permanently reside in the U.S., or do not intend to reside in the U.S. but intend to own U.S. property, need considerable legal and tax planning. The definition of “U.S. property” for...more

Practice Aid – A Redlined Version of the Proposed Section 2701 and 2704 Regulations

These proposed regulations are difficult enough in substance to deal with, without having to piece together the changes that they make to the existing regulations. Maybe there is a redlined version out there already, but I...more

Thinking of Crowdfunding Your Project? Beware – the Taxman Cometh

The IRS Office of Chief Counsel recently released Information Letter 2016-0036 in response to questions regarding the taxation of crowdfunding revenue. In it the IRS concluded that crowdfunding revenue is taxable to the...more

Dubai Airport Freezone Authority

Dubai Airport Freezone (DAFZA) is one of the region’s fastest growing Freezones. Established in 1996, DAFZA is home to over 1,450 companies, covering a range of key industry sectors, including aviation, freight & logistics,...more

AccountingToday Article Provides Tax Primer: “Global Commerce 101”

Owners of small to mid-size U.S. businesses are finding the world is a smaller place, which can be very good for business. However, the opportunities of the international marketplace come with additional responsibilities,...more

Calif. Firms Struggle To Find Exchange Properties Amid Boom

Bob Baradaran was quoted in an August 10, 2016, article by Law360 reporter Andrew McIntyre about the real estate boom in California (subs. req.) and the impact that boom is having on 1031 like-kind exchanges commonly used to...more

IRS Eliminates Requirement to Submit Copy of Section 83(b) Elections with Tax Return

The IRS adopted final regulations that no longer require taxpayers who have made Internal Revenue Code §83(b) elections to attach a copy of the election to their annual federal income tax return. Under §83, restricted...more

IRS Proposed Regulations Attack Valuation Discounts for Family Transfers — The Clock Is Now Ticking

The U.S. Department of the Treasury and the IRS have just issued anticipated proposed regulations that, if made final, would severely limit the ability of taxpayers to transfer interests in family limited partnerships and...more

MoFo New York Tax Insights - Volume 7, Issue 8

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

Pennsylvania Tax Changes and Tax Amnesty Program

As part of the budget package, the Pennsylvania General Assembly made many significant changes to various Pennsylvania tax laws and the unclaimed property law (including a tax amnesty program) that are estimated to generate...more

Proposed Treasury Regulations Provide Additional Flexibility, Clarity and Planning Opportunities to Sponsors of Deferred...

The IRS recently issued proposed regulations under Internal Revenue Code Section 457 that address, among other things, the interplay between Code Section 457(f) and Code Section 409A. Additionally, the IRS issued clarifying...more

Sonhos Interrompidos - Como uma não conformidade tributária pode destruir o Sonho Americano de imigrantes não registrados - Parte...

Panorama - As eleições presidenciais dos EUA entraram em uma fase de disputa com os partidos Republicano e Democrata realizando suas convenções nas próximas duas semanas para escolher Donald Trump e Hillary Clinton como...more

Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights [Video]

Sutherland SALT tracks and tallies significant state and local tax litigation wins and losses in the quarterly Sutherland SALT Scoreboard publication. In this videocast, Charles C. Capouet and Elizabeth S. Cha share the...more

Blog: Share Incentives for Employees of Private UK Companies

Companies generally consider it a good idea for employees to be stakeholders in the business in which they work and believe share-based incentives offer the ability to reward, motivate and retain key staff. There are...more

Executrix Held Liable Under Federal Claims Statute For Actions Taken Prior to Appointment as Executrix

A decedent died while owing over $340,000 in unpaid federal income tax liabilities. His estate was insolvent. The assets of his estate consisted almost entirely of a 100% interest in one corporation and 50% of another...more

New VAT regime for e-services

On 1 January 2017 the special VAT regime for "electronically supplied services" ("e-services") comes into effect, as introduced by Federal Law No. 244-FZ dated 3 July 2016....more

Personal Planning Strategies - August 2016

Low Interest Rates Yield Wealth Transfer Opportunities - Low interest rates can create wealth transfer opportunities. For various wealth transfer techniques, the IRS assumes that a certain minimum interest rate is in...more

IRS Wins Debt vs. Equity Case

A frequent area of dispute between taxpayers and the IRS is whether an indebtedness obligation should be treated as debt, or an equity investment, for income tax purposes. Taxpayers often seek debt treatment to obtain...more

IRS Provides Guidance for Making an 83(b) Election

On July 25, 2016, in T.D. 9779, the IRS published final regulations concerning the procedures for making an election under section 83(b) of the Code. The new final regulation, Treas. Reg. §1.83-2, eliminates the requirement...more

The Cost of Clarity: IRS Issues Regulations Addressing Proper Treatment of Code Section 50(d) Income

On July 21, 2016, the IRS issued long-awaited regulations under Section 50 of the Internal Revenue Code (the “Code”) clarifying the manner in which “Section 50(d) Income” is to be recognized in lease pass-through investment...more

IRS Issues Proposed Rules on Income Inclusion under Section 50(d)(5)

The IRS just published long-awaited temporary regulations under section 1.50-1T governing the section 50(d)(5) income inclusion rules. These rules apply to lessees of investment credit property when the lessor elects to treat...more

Under the Dome: Inside the Maine State House

Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. Maine Sees Higher Budget Surplus Than Expected - On June 30, 2016, Maine’s fiscal year ended...more

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