Income Taxes Business 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

Recent New Jersey Tax Court Decision Creates Income Tax Refund Opportunity

In the recently decided case PPL Electric Utilities Corp. v. Director, Drinker Biddle was successful in convincing the New Jersey Tax Court that neither the Pennsylvania capital stock tax nor the gross receipts tax are...more

Inbound Acquisitions At A Glance - Update 2014

We are delighted to provide you the third edition of our “Inbound acquisitions at a glance” brochure. In today’s increasingly complex business environment, awareness of the tax environment in relevant jurisdictions is...more

Tax Reminders? Now There’s an App For That

We have previously blogged about litigation apps and the absence of Canadian litigation and tax litigation apps. Yesterday, the Canada Revenue Agency introduced a new tool for tax compliance with the release of the...more

The Corporate Inversion: From Obscure Strategy to Hot Trend

Capitalist ideals of “free enterprise” and “competition” make great debate topics, but when compared to the business-friendly tax codes of other nations the United States Tax Code cannot compete. With the highest corporate...more

Reed Smith Wins Toyota Credit Case in New Jersey Tax Court

On Friday, August 1, in a corporation business tax case handled by Reed Smith, the New Jersey Tax Court ruled that Toyota Motor Credit Corp. was entitled to recompute its tax by reducing gains on the sale of leased vehicles....more

Are You My Partner? Considerations for Structuring Business Transactions

When entering into a business arrangement where revenues are shared between two or more persons, it is necessary to consider whether those parties have become partners either for state law or tax purposes. No express intent...more

Analysis: The Tax And The City Briefing For July

Redemption payments - The Court of Appeal (CA) has made short work of a case where loan stock was issued without interest but with a right to redemption proceeds of 7.25% per annum on the principal amount. The outcome...more

New York State Tax Reform Update

Qualified manufacturers subject to the New York State Business Corporation Tax may now pay no tax on business income earned in New York....more

Missouri Legislature Overrides Governor Nixon To Pass Tax Cut Bill

In this issue, we address important new Missouri tax changes that were passed on May 6, 2014 after the Missouri Legislature overruled Governor Jay Nixon's veto. The legislation modifies the individual income tax rate table by...more

IRS Changes Position on Certain Income Earned by State-Chartered Credit Unions

In a recent memorandum (found here), the IRS issued instructions to all exempt organization examiners on the applicability of unrelated business income tax (“UBIT”) to certain income earned by state-chartered credit unions...more

Taxation of Carried Interest Under Chairman Camp’s Tax Reform Proposal

On February 25, 2014, House Ways and Means Committee Chairman Dave Camp (R-MI) issued a sweeping tax reform discussion draft, numbering almost 1,000 pages (the Discussion Draft). This alert summarizes proposals included in...more

Proposed Section 752 Regulations Would Prohibit Bottom Guarantees And Impose Net Worth Requirements In UPREIT Transactions

The IRS has recently proposed regulations under Section 752 of the Code which, if finalized in current form, would radically change the use of guarantees in partnership transactions. Under these regulations, bottom guarantees...more

Proposed Carried Interest Legislation Takes A Different Approach

On February 26, 2014, U.S. Rep. David Camp (R-MI), chairman of the House Ways and Means Committee, released a draft of the Tax Reform Act of 2014 (TRA 2014), which would provide for the most significant tax reform since the...more

Representative Dave Camp’s Proposed Draft Legislation on Tax Reform

Last week, Representative Dave Camp (R-MI), Chairman of the House Committee on Ways and Means, unveiled draft legislation on tax reform that would include a 10 percent tax on municipal bond interest for joint filers with...more

LLPs and taxation of "disguised employment" – no delay to implementation

Is your business operating in the UK in “Limited Liability Partnership” (“LLP”) form? If so, it may be affected by a tax reform from 6th April 2014, requiring immediate compliance steps....more

Tax Court Ruling Impacts the Treatment of Income Allocations Attributable to Unvested Partnership Capital Interests

The United States Tax Court recently issued its opinion in Crescent Holdings, LLC v. Commissioner, 141 T.C. No. 15 (12/2/13), a ruling regarding allocations of income attributable to an unvested partnership interest. The...more

The Oil and Gas Law Review: United States: California

In This Review: - I Introduction - II Legal And Regulatory Framework - III Licensing - IV Production Restrictions - V Assignments Of Interests - VI Tax - VII Environmental...more

Doing Business in Japan

I am pleased to present to you DLA Piper’s “Doing Business in Japan” Guide. Japan is the world’s third largest economy and remains cutting-edge in business. In 2012, 68 Global 500 Companies were headquartered in...more

Do You Operate Out of a Home Office? The IRS Wants to Simplify Your Life - But Don't Celebrate Too Quickly!

If you use part of your home for business, you may be able to deduct expenses for the business use of your home. The home office deduction is available for homeowners and renters, and applies to all types of homes. A...more

California Enterprise Zone Program Modified with New Incentive Programs - New Economic Development Tax Credits Available for...

Yesterday, Governor Brown signed into law AB 93, legislation that will institute two new tax exemption programs for manufacturing and bio-tech equipment, add a hiring credit for employment in specified geographic areas and...more

Spotlight on Tennessee: 2013 Tax and Related Legislation

The 2013 Session, 108th General Assembly, considered numerous tax and related initiatives, many of which passed. The subject matter of these initiatives this year was very broad, ranging from efforts toward amending the...more

Senate Finance Committee Asks Members to Communicate Tax Reform Priorities

On June 27, Senate Finance Committee Chairman Max Baucus (D-MT) and Ranking Member Orrin Hatch (R-UT) released a Dear Colleague letter laying out a beginning framework for comprehensive business and individual tax reform. ...more

Michigan Court Allows Multistate Tax Compact Election

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

McAfee & Taft AgLINC - May 2013: Significant changes in tax rates in store for 2013 and beyond

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 Pinch of SALT: State Tax Treatment of a 'Manufacturer'

Originally published in State Tax Notes. Many states have created special treatment for manufacturers, including tax exemptions, credits, and special income tax apportionment rules. In this edition of A Pinch of SALT, we...more

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