News & Analysis as of

Tax Allocation Agreements

Update on Transaction Costs - 'Origin of the Claim' Analysis Will Decide Tax Allocations - Tax Update Volume 2017, Issue 3

by Pepper Hamilton LLP on

While the Internal Revenue Service (IRS) has continued to issue guidance addressing the ability to deduct transaction costs, the doctrine of "Origin of the Claim" (OOC) developed over 50-plus years of case law is still the...more

California Debt Limit Allocation Committee Releases Proposed Regulations

This client alert discusses some of the more significant changes that could affect issuers and borrowers in connection with awards of volume cap if the proposed regulations were adopted in their current form. The...more

New Regulations Dramatically Alter Partnership 'Disguised Sales' and Allocation of Partnership Liabilities

On October 4, 2016, the Internal Revenue Service and the Treasury Department issued a sweeping package of proposed, temporary and final regulations under the Internal Revenue Code that, among other things, significantly...more

Surplus Lines Clearinghouse Provides Instructions Following The Dissolution Of The Non-Admitted Insurance Multistate Agreement...

by Carlton Fields on

In a Special Focus article posted on May 2, 2016, we addressed the uncertain future of the multi-state allocation of non-admitted premium tax revenue. The Non-admitted and Reinsurance Reform Act (NRRA) provides for individual...more

DC Circuit Ruling Threatens to Topple FERC Tax Allowance Policy

by Morgan Lewis on

Court rules that FERC policy permitting a tax allowance for pass-through entities may unjustifiably permit “double-recovery” of tax expense. On July 1, the US Court of Appeals for the District of Columbia Circuit issued...more

DC Circuit Decision Likely to Reignite FERC Debate Over Tax Allowance for Pass-through Entities

by Cozen O'Connor on

The recent decision by the U.S. Court of Appeals for the District of Columbia Circuit in United Airlines Inc., et al., v. Federal Energy Regulatory, Case No. 11-1479, July 1, 2016 (United Airlines) will likely reignite a...more

Delaware Chancery Court Dismisses Challenge to MLP Drop Down Transaction

by Bracewell LLP on

The Delaware Chancery Court recently dismissed a challenge to a transaction in which a master limited partnership (the "MLP") repurchased an interest in a crude oil pipeline in 2015 previously sold to its general partner (the...more

What Is The Future Of The Multi-State Allocation Of Nonadmitted Premium Tax Revenue?

by Carlton Fields on

In the portion of the Dodd-Frank Act known as the Nonadmitted and Reinsurance Reform Act, Congress established a public policy and stated its desire that “each State adopt nationwide uniform requirements, forms, and...more

Temporary Regulations Address Allocation of Creditable Foreign Tax Expense

by Goulston & Storrs PC on

The IRS published temporary and proposed regulations on allocations of creditable foreign tax expenditures (CFTEs).  The regulations make various technical changes to the existing regulatory safe harbor for allocating CFTEs. ...more

Allocation, Due Diligence, and More Record Keeping! New Draft Regulations on New York State’s Corporate Income Tax Allocation

by Hodgson Russ LLP on

2014 brought significant corporate income tax reform to New York State. This year, 2015, followed suit and brought many of those same corporate income tax reforms to New York City. To quote Donald Trump, these reforms are...more

Status Update on Targeted Allocation Regulations

I’m at the ABA Tax conference this week and one of this morning’s first panels included a discussion of hot topics in partnerships. Curtis Wilson, IRS Associate Chief Counsel in Passthroughs and Special Industries,...more

IRS Slams Profits Interests In Lieu of Management Fees and More

by Goulston & Storrs PC on

The IRS issued the much anticipated proposed regulations that severely curtail the practice of a fund manager waiving management fees in exchange for a share of future partnership profits. In essence the regulations tighten...more

CDFI Fund Releases Updated Compliance FAQ

by Ballard Spahr LLP on

On Friday January 2, the CDFI Fund released an updated Frequently Asked Questions document for New Markets Tax Credit (“NMTC”) questions relating to certification, compliance monitoring, and evaluation. The updated FAQ...more

October 31 Amendment Deadline for Bank Holding Company Tax Allocation Agreements

by Baker Donelson on

On June 19, 2014, the federal banking agencies issued a final Addendum to their Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure which may require non-S corporation bank holding company...more

Final Supplemental Guidance on Income Tax Allocation Agreements: Why It’s Important to Act Now

by GableGotwals on

Almost every bank and its holding company (“HC”) conduct business with each other, typically through an agreement whereby one performs services for the other in return for some consideration. The bank, for example, may...more

Supplemental Interagency Guidance on Tax Allocation Agreements

by Ballard Spahr LLP on

The federal bank regulators recently issued additional guidance on intercompany income tax allocation agreements between holding companies and their depository institution subsidiaries. Intended to clarify the ownership of...more

Bank Holding Companies Must Review Their Tax Allocation Agreements With Subsidiary Banks Now!

Taxes remain a certainty in life, but in an effort to reduce confusion regarding the ownership of tax refunds—particularly in light of court opinions reaching varying conclusions when considering failed banks—the Board of...more

Federal Banking Agencies Issue Final Version of Addendum to Interagency Policy Statement on Income Tax Allocation

by Goodwin on

The FRB, FDIC and OCC (collectively, the “Agencies”) issued a final version of an addendum (the “Addendum”) to their “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure” (the “Policy...more

Bank Regulators Require Changes To Tax Allocation Agreements

by Dickinson Wright on

Acting in response to divergent results in recent court decisions, the Federal bank regulatory agencies have adopted an Addendum to their longstanding rules regarding income tax allocation agreements between insured...more

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