On June 6, 2013, the Internal Revenue Service issued Revenue Ruling 2013-14, which concludes that a Fideicomiso or a Mexican Land Trust (MLT) is not taxed as a “trust” for U.S. income tax purposes. While most practitioners...more
A couple of weeks ago, the Minnesota Legislature passed new tax legislation that, among other things, added a brand new Minnesota gift tax and expanded the applicability of the Minnesota estate tax. A summary of the entire...more
Although it may come as a surprise to many, it is no secret that South Florida property values are on the rise. ...more
There is absolutely nothing wrong with having a foreign bank account. The problem comes along when the existence of the account is not disclosed and income associated with the account is not reported....more
In this article: - Income Tax - Other Foreign Taxes -- Vat And Social Security Taxes - Foreign Tax Credit Planning - U.S. Withholding Obligations - Use Of Loan Out Company -...more
Employers providing benefits for employees' same-sex spouses may want to consider the availability of federal payroll tax refunds if the Supreme Court of the United States finds Section 3 of the Defense of Marriage Act (DOMA)...more
In this presentation: - Eligible Organizations: Those qualified under Section 501(c)(3) of the Internal Revenue Code. - More complicated than the typical bank loan. - To qualify for tax exemption, the...more
On June 6, 2013, the Michigan Court of Claims became the second court in the country to hold that the Multistate Tax Compact (the Compact) is a binding multistate compact that cannot be repealed by a separate, subsequent...more
On June 6, 2013, at the Toronto Centre CRA & Professionals Breakfast Seminar, the Canada Revenue Agency discussed (a) recent developments at the Income Tax Rulings Directorate and (b) the process through which the General...more
Cyprus has been a member of the European Union since 2004. The country has long been known for its low corporate income tax rate and absence of withholding taxes on payments of interest, dividends and royalties paid to...more
Despite the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) publishing final regulations for reporting bank accounts, securities accounts and other financial accounts located in a foreign country on...more
New York Governor Andrew Cuomo has proposed “Tax-Free NY,” a plan that would create tax-free status for new businesses on the State University of New York’s 64 campuses and the nearly 200,000 square feet around their...more
Topics include: - Australia: ..Budget 2013-14: Government Targets Multinationals to Recover from GFC - China: ..Recent Anti-avoidance Cases in China ..SAT Interprets Capital Gains Provisiosn in...more
China’s State Administration of Taxation (“SAT”) released Bulletin [2013] No. 19, “Announcement on Issues Concerning Levying Corporate Income Tax on Services Provided by Non-residents through Seconding Personnel to China”...more
In Harley-Davidson, Inc. & Subsidiaries v. California Franchise Tax Board (May 1, 2013), the San Diego Superior Court held that special purpose entities (SPEs) created by the plaintiff as securitization subsidiaries had...more
Governor Dayton signed the new Minnesota Omnibus Tax Bill (HF 677) on May 23, 2013. While there has been media coverage regarding the changes to the sales tax, you may be less familiar with the Minnesota income, gift, and...more
Code §368(a)(1)(F) facilitates the movement of corporations from one jurisdiction to another by generally treating such reorganizations as not being subject to corporate income tax at the corporate or shareholder level....more
The Alabama Legislature adjourned near midnight on May 20, closing a session that saw lawmakers grant final passage of the two operating budgets and of amendments to the controversial Alabama Accountability Act. With respect...more
In dramatic fashion, and with some historic footnotes, the 2013 Minnesota Legislature concluded its work last week....more
According to a recent study, Tennessee ranked at the top of a list of the 10 best states where retirees should spend their golden years. Tennessee is considered the best state for retirement based on its rating in several...more
The American Taxpayer Relief Act of 2012 (2012 Tax Act) and the Patient Protection and Affordable Care Act (Affordable Care Act) combine to produce significant changes in tax rates for 2013 and future years. The 2012 Tax Act...more
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
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
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
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
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