On October 2, in PPL Electric Utilities Corporation v. Director, Division of Taxation, No. 000005-2011, the New Jersey Tax Court determined that federal deductions for the taxpayer’s payments of Pennsylvania gross receipts...more
The federal estate tax marital deduction is one of the most important estate planning tools available to a married couple. The basic marital deduction rule is that, upon the death of the first spouse, the value of any...more
Especially if you have significant wealth, planning carefully for your future and the future of your loved ones is vital. Although many people are familiar with the basics of estate planning, from drawing up a will to naming...more
In Devon Canada Corporation v. The Queen the issue is whether the taxpayer (“Devon”) may deduct $20,884,041 paid to cancel issued stock options. After the close of pleadings, the Crown brought a procedural motion relating to...more
“A tax loophole is something that benefits the other guy. If it benefits you, it is tax reform.” – former U.S. Senator Russell B. Long (D – Louisiana).
“The precise point at which a tax deduction becomes a ‘loophole’...more
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
In an appeal by HMRC against a decision of the First-tier Tribunal ("FTT"), the Upper Tribunal (Tax and Chancery Chamber) ("UT") decided that a penalty imposed on McLaren Racing Limited ("McLaren") in respect of a breach of...more
Appellate court affirms $50 million tax refund to FCA defendant, holding that the “economic realities” of settlement payments determine whether they are compensatory.
Civil False Claims Act (FCA) settlements, which...more
On August 13, 2014, the United States Court of Appeals for the First Circuit affirmed a district court’s judgment in a tax dispute proceeding that Fresenius Medical Care Holdings, Inc. (Fresenius) was entitled to more than...more
Students will soon be heading back to school, and with skyrocketing education costs, families are increasingly exploring ways to cut costs and save money. With that in mind, in this Alert, we summarize what many consider the...more
The following is a summary of the most important tax developments that have occurred in the past several months that may affect you, your family, your investments, and your livelihood. Please call us for more information...more
In Spruce Credit Union v. The Queen (2014 FCA 143) the Federal Court of Appeal upheld the lower court’s interpretation and application of the inter-corporate dividend deduction under subsection 112(1) of the Income Tax Act...more
The Spanish Government has asked an experts committee to prepare a report with proposals for the tax reform that the Spanish Government is currently drafting.
One of the proposals of the committee is to establish a new...more
In This Issue:
- Staying in Compliance While Giving or Receiving Electronic Health Record Systems
- When Donations Cross the Line
- House Bill 296 Signed into Law to Increase Access to Epinephrine Autoinjectors...more
SPEED READ -
The Upper Tribunal has upheld the Firsttier Tribunal’s (FTT’s) decision in Greene King. Planning designed to obtain a deduction with no taxable receipt was held to have failed. While the law has changed...more
In a previous post earlier this week, I described the proposed regulations under Section 752 of the Internal Revenue Code (the “Proposed Regulations”), and in particular, the proposed changes to the rules regarding the...more
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
The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of recent legislation around the U.S.
On May 8, 2014, the Internal Revenue Service published final Treasury Regulations, §1.67-4, prescribing when costs incurred by estates or nongrantor trusts are subject to the 2-percent floor for miscellaneous itemized...more
Late last year, the IRS and Treasury Department released final and proposed regulations that affect the tax treatment of costs associated with plants, buildings, equipment, and machinery. These rules affect the costs...more
In This Issue:
- High Court Considers Whether Corporations Can Lie to Investors
- Nasdaq Enters Pre-IPO Market with Private Exchange
- Many Early-Stage Start-Ups Still Struggle to Get Funding
It’s a dilemma that many cottage owners face: you want to earn extra money while away from your cottage but you are worried about the hassles that come with owning a rental property. It is well known that renting out a...more
On February 26, 2014, U.S. Congressman Dave Camp released a comprehensive tax reform proposal that includes several provisions intended to limit or restrict executive compensation. Congressman Camp’s proposal includes the...more
On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more
April 15th is approaching and it is time to begin crossing T's and dotting I's in preparation for paying taxes. As tax time draws near, you want to make sure you file all the proper forms and take all deductions you're...more
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