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

Southeast State & Local Tax: Important Developments - November/December 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast....more

NYS Tax Department Reverses Position on Statutory Residence Rule

The New York State Department of Taxation and Finance (the Department) has backed off from an aggressive position that it has been taking in cases involving New York residence issues....more

International Tax News - December 2014

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS - The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015. The government has published...more

2014 Year-End Tax Update

I. A LOOK BACK AT 2014 TAX MATTERS: A. Some Random Observations - ..1. This year’s update is brought to you by the letter “I,” as in “inversions.” ..2. Tired of waiting for Congress to address what they...more

Five Things You Should Know About New York State’s Taxation of Convertible Virtual Currency

On December 5, 2014, the New York State Department of Taxation and Finance issued TSB-M-14(5)C, (7)I, (17)S, explaining its policy regarding convertible virtual currency....more

Alabama Tax Developments – 2014 Year in Review

This SALT Alert summarizes the major legislative, judicial, and administrative developments affecting Alabama business taxpayers with respect to income, transactional, and property taxes, as well as several updates on...more

India Amplifies Compliance Norms for Wealth Tax Purposes

In a recent development, the compliance norms for wealth tax purposes in India have been amplified. Accordingly, overseas assets of persons subject to Indian wealth tax, including...more

Charitable deductions: Substantiate them or lose them

Qualifying for a charitable deduction is, in some respects, a matter of form over substance. The IRS could disallow a deduction, even if it’s otherwise legitimate, if the donor fails to follow the substantiation requirements...more

Guindon: SCC Hears Arguments in Penalty Case

The Supreme Court of Canada heard oral arguments today in the case of Guindon v. The Queen (Docket No. 35519). At issue in the case is the nature of the third-party penalty in section 163.2 of the Income Tax Act....more

2014 Extenders Clear the House

For many years now, Congress has contributed to tax uncertainty by extending certain favorable tax provisions on a year by year basis. Thus, for example, in 2014 these extenders have expired. Neither the IRS, who has to...more

Residency vs. Domicile

“Place of residency” and “place of domicile” may appear to mean the same thing, but may have different definitions at tax time. The definitions are similar if you have lived in the same place for many years, but if you...more

Year-end Uncertainty Highlights Need for Tax Reform

As we approach year-end, we again find ourselves in an all-too-familiar and unsettling situation — one in which we do not know the rules of the game we are about to play. Many popular tax planning opportunities, like the R&D...more

State and Local Taxation: Headline News and Trends (CPE/CLE) [Video]

In this fast-paced presentation, David Fruchtman (chair of State and Local (Subnational) Taxation at Rimon P.C.) analyzes the most important developments in multistate and local tax legislation, case law and administrative...more

Focus on Tax Strategies & Developments - November 2014

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

Courts Uphold Supplemental Assessment of Wells and Related Facilities/Improvements; and Validate Use of Cost Approach

The County of Kern Tax Assessor’s (“Assessor”) use of the cost approach to value to appraise new oil and gas wells for the purpose of levying supplemental assessments has been upheld by the Fifth District Court of Appeal. In...more

Taxation of Convertible Virtual Currency, Part II: Taxation of Virtual Currency Income

In Part I of this series, we discussed the IRS guidelines on the taxation of gains and losses associated with convertible virtual currency. In this post, we will focus on the taxation of income--wages, self-employment income...more

IRS Provides Protection against Upcoming Change in Rollover Rules

Today, in Announcement 2014-32 (the "Announcement"), the Internal Revenue Service clarified the rules that will apply going forward when an owner of an individual retirement arrangement (IRA) seeks to roll over a distribution...more

Cashing Out of a Partnership – The Joy of Distributions

While partners usually groan upon receiving capital calls, they are delighted to receive distribution checks. However, provisions regarding distributions can be convoluted and require more than perfunctory consideration. Any...more

Bye Bye Brazil – Considerações Tributárias no Planejamento de Investimento Brasileiro dentro dos Estados Unidos - Parte 1

Sou advogado tributário americano. Me formei na academia militar do exército americano em West Point, Nova Iorque. Me graduei em Espanhol e Português. Meus professores eram um tentente coronel do exercito brasileiro formado...more

Interest Deductions When Interest Added to Principal Balance

A cash basis taxpayer owes interest and principal to a lender on a home mortgage loan. The taxpayer goes to another lender, borrows additional money against the residence, and uses the loan proceeds to pay off the accrued...more

McKesson: Taxpayer Seeks to Raise Additional Issue on Appeal

The transfer pricing case of McKesson v. The Queen has raised procedural issues that are without precedent in Canadian tax cases. This week, those procedural issues became a central part of the matters that will be considered...more

A Taxing Problem: How to Regulate Online Vacation Rental Marketplaces

In recent years, the “sharing economy” has developed across the country. It is largely unregulated and, as such, can operate contrary to the interests of local businesses and communities. These “sharing” services are complex...more

OECD Countries Agree To Share Tax Information

On October 29, representatives from 51 countries, having met at the Global Forum on Transparency and Exchange of Information for Tax Purposes, agreed to address tax havens in exchange for transparency in tax information....more

Three Year-End Tax Tips

If divorcing your spouse is not difficult enough, those who are not legally divorced by December 31 must begin thinking at this time of year about tax planning as “married” individuals. The issue of tax filing becomes an...more

Orwell’s 1984 30 Year Later

Welcome to 1984 30 years later! One of the most famous quotes from George Orwell’s 1984 is “Big Brother is Watching You.”. This quote is more true now than at any time in past. At the just concluded Global Forum on Tax...more

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