Monthly Minute | January 2020
The characterisation of fixed and floating charges remains a complex area, not least with respect to new intangible asset types. The key distinction between a fixed and a floating charge is well established as a matter of...more
Late in the evening of July 7, 2022, Governor Tom Wolf signed Act 53 of 2022 (Act 53) into law. Act 53 significantly modifies the corporate net income tax (CNIT), subjects certain ride-sharing agreements to sales tax,...more
Pennsylvania’s 2022-2023 budget, Act of Jul. 8, 2022, P.L. __. No. 53 (Act 2022-53) (HB 1342) implements sweeping tax reform and revises some of Pennsylvania’s most business-unfriendly tax provisions. The bill will:.....more
Don’t Do It- There are certain generally accepted “dos and don’ts” of which almost every investor is certainly aware. For example, do not put all your eggs in one basket; if an investment seems too good to be true, stay...more
Retailers and brand owners should be mindful of recent UK tax developments that impact taxation of gross receipts and taxation of digital activities. The new income tax charge on offshore receipts from intangible property...more
The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more
In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
Several press articles in recent weeks have anticipated the upcoming enactment of the Ministerial Decree which will eventually implement the Italian Patent Box regime. The Ministry of Economics and Finance announced on 29...more
In This Issue: - Important Changes at NYS and NYC Tax Agencies - Court of Appeals Upholds Constitutionality of Taxing Nonresidents on Gain from S Corporation Stock Sale in Two Separate Decisions - NYC Tribunal...more
In a case argued by Stoel Rives, the Oregon Supreme Court upheld the judgment of the Oregon Tax Court in favor of Tektronix, Inc. The Supreme Court ruled that, for purposes of apportioning income, the sales factor excluded...more
The Tennessee Department of Revenue issued Notice 13-06 in June notifying taxpayers that its acceptance of voluntary disclosure of intangible expense deductions at a preferred settlement rate will be ending later this year....more
Representative Dave Reed (R-Indiana Co.), with more than fifty co-sponsors, has reintroduced legislation (H.B. 440) that would require corporations preparing PA Corporate Net Income Tax returns to add-back any “intangible...more