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

Cupid’s Arrow Strikes Lover in the Wallet

Revenge is a dish best served cold. In a recent case, a disenchanted suitor not only sued to recover gifts he made to his former lover but also reported those gifts to the IRS as income payments! See Diane Blagaich, TC Memo...more

Virginia Trial Court Rules Against Taxpayer in Addback Case

In a case of first impression, the Richmond City Circuit has determined that Virginia’s “subject to tax” exception to intangible expense addback only applies to the portion of the royalty that the recipient included in its...more

Cross-Border Banking and Out-of-this-World Penalties - Dealing with the IRS when you have Foreign Bank Accounts

A United States citizen or resident that owns (or has signatory authority over) an account at a foreign bank with a value in excess of $10,000 annually must file a Report of Foreign Bank and Financial Account (or “FBAR”) with...more

Federal Appellate Court Rules that Certain Foreign Currency Options Are Subject to the Section 1256 Mark-to-Market Regime

Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options (and also, possibly, to foreign currency...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. Legislature Delays Passage of a Tax Conformity Bill - The Appropriations Committee worked on...more

Trusts and taxes - Understanding how one affects the other can benefit your estate plan

Trusts typically are a main component of an estate plan. But many may not know how higher taxes can impact a trust’s overall effectiveness. This article explains how the current tax environment affects trust planning....more

DOJ’s Latest Offshore Tax Case Shows Expatriates Who Renounce U.S. Citizenship Not Immune From Prosecution

An individual residing in Switzerland since 2007, who apparently renounced his U.S. citizenship four years ago, was convicted today in federal court of one count of filing a false U.S. income tax return. According to a...more

MoFo Tax Talk - Volume 8, No. 4

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

Alabama Department of Revenue Proposes Changes to its Corporate Income Tax Apportionment Regulations

The Alabama Department of Revenue (ADOR) recently proposed numerous changes to its apportionment rules for corporate income taxpayers, with the stated intention of adopting “recommended amendments to the [Multistate Tax...more

Singapore’s Income Tax (Amendment) Bill 2016

Upcoming changes to the Exchange of Information framework hints at future adoption of the Organisation for Economic Co-operation and Development’s Common Reporting Standards. The crux of Singapore’s Income Tax...more

New FIRPTA Changes Provide Significant Opportunities, But No Panacea for Encouraging Non-U.S. Investment in U.S. Real Estate

Under FIRPTA, a non-U.S. person’s gain from the sale of U.S. real property interests is treated as income that is effectively connected with a U.S. trade or business (“ECI”), and therefore, is subject to U.S. federal income...more

How to Make Sure You Don't Lose Your Charitable Contribution Deduction

In order for a U.S. taxpayer to deduct contributions to charity on his or her federal income tax return (Form 1040), the taxpayer must comply with very specific rules set forth in the Internal Revenue Code (the “Code”) which...more

Justice Department Opens 2016 Tax Season With Stern Warning to Taxpayers

The Internal Revenue Service announced that the 2016 individual income tax filing season opened on January 19, 2016, with more than 150 million returns expected to be filed. The IRS expects more than 70 percent of taxpayers...more

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

PATH Act Changes to FIRPTA

The Protecting Americans from Tax Hikes Act of 2015 (the PATH Act, Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) made some important changes to the U.S. federal income tax...more

Form W-2 and 941 Actions May Be Required Immediately for Retroactive Increase in Section 132 Transit Benefits

The Consolidated Appropriations Act of 2016 (the Act) retroactively increased the 2015 employer and employee Federal Insurance Contributions Act (FICA) and Federal Income Tax exclusion limit for transit benefits, from $130...more

"Major Changes to Tax Audit Procedures to Impact Most Partnerships"

Legislation enacted in November 2015 will fundamentally change the way the Internal Revenue Service (IRS) examines entities treated as partnerships for U.S. federal tax purposes, including how it assesses and collects tax...more

100 Percent Exclusion for Qualified Small Business Stock Finally Made Permanent

Among the many “tax extenders” in the Protecting Americans from Tax Hikes Act of 2015 (PATH Act, Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) is a permanent extension of...more

Several Key Business Associations Announce 2016 Tax Legislative Agendas

In preparation for the 2016 regular session, which begins on February 2, several of Alabama's key trade and business organizations recently announced their tax legislative agendas. As reflected in these agendas, the 2016...more

Annual Estate Planning Newsletter: Part One

Action Item: This year, Blank Rome’s annual estate planning newsletter will be issued in six installments. Each installment will discuss certain concepts and techniques that we hope may be of interest to our clients and...more

Congress Extends Various Tax Benefits

There has been a long history of various tax benefits being extended for short periods. In many recent years, Congress has enacted provisions late in the year, often in December, to extend various provisions for another...more

MoFo New York Tax Insights - Volume 7, Issue 1, January 2016

The Top 10 New York Tax Highlights of 2015 - This past year turned out to be another eventful one in New York taxation. We continue our tradition and present our list of the Top 10 New York tax highlights of...more

Tax Considerations in Real Estate Dispositions

In a typical real estate transaction, the seller deeds the real property to the buyer. This transaction is simple and straightforward for both buyer and seller. Although it is simple, is it the best structure from a tax...more

U.S. Pre-Immigration Tax Planning

The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more

The Tax Man Cometh Not to ID Protection Recipients Either

Late last year, while you were probably busy picking out which bubbly to pop at the stroke of midnight, the IRS gave us another reason to celebrate. You may remember (as we wrote previously) the IRS said it would not require...more

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