Tax Deductions

News & Analysis as of

New Jersey Refund Opportunities Associated with the Deductibility of Other States’ Taxes

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 Marital Deduction: A Valuable Estate Planning Tool

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

The Unlimited Marital Deduction & Non-Citizen Spouses

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

Devon: TCC considers large corporation rules

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

The Eye of the Beholder

“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

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

No UK corporation tax deduction for penalty imposed under the code of the Fédération Internationale de l'Automobile ("FIA")

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

First Circuit Liberalizes Tax Deductibility Standard of False Claims Act Settlements

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

First Circuit Rules in Favor of Dialysis Operator in Tax Dispute

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

Back to School: Tax Benefits for Education

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

Recent Tax Developments

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

Spruce Credit: Avoidance transactions and the Duke of Westminster

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

Spain: New limits to the tax deductibility of interest

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

Perspectives - June 2014

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

UK's Upper Tribunal decision in Greene King: tax and accounting

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

Proposed Section 752 Regulations and LIHTC Transactions: Part II

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

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

Southeast State & Local Tax: Important Developments - April Update

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. ...more

Final Regulations Issued For Investment Advisory Fees and Other Costs Incurred By Trusts and Estates Subject to the 2-Percent...

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

Complying With The Tangible Property Regulations – Procedural Guidance Provides Favorable Rules That Require Immediate...

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

Corporate & Tax E-Note - March 27, 2014

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 - Venture...more

Rental Cottages And Limits On Federal Income Tax Deductions

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

Tax Reform Proposal Takes Aim at Executive Compensation

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

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

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

Things to Remember at Tax Time

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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