Tax Deductions

News & Analysis as of

Top Ten International Anti-Corruption Developments for May 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

New Hampshire Enacts Business-Friendly Tax Changes

Three business-friendly tax bills have become law in New Hampshire. Each bill will result in tax reductions for those able to take advantage of them. The New Hampshire Business Profits Tax generally “piggybacks” on the...more

EU Council Agrees on Final Anti Tax Avoidance Directive

We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more

Recreational Cannabis — Section 280E and Tax Efficient Structuring

I. The Conflict: The long arm of federal law Recreational cannabis businesses operate in a world of conflicting state and federal laws. Several states have legalized recreational cannabis, yet, under federal law, cannabis...more

UK tax deductibility of corporate interest expense

The 2016 Budget announced, and the UK government is currently consulting on, the biggest change in UK tax this century. Up until 1st April 2017, a tax deduction for interest costs of up to 100% of UK profits is (very broadly)...more

Considerations for C Corporations Making a 2016 Conservation Easement Gift

When considering making a conservation easement gift, there are a number of steps involved, including the creation of multiple documents, appropriate due diligence and other tasks required to implement and substantiate such a...more

Charitable Remainder Trusts: A Viable Strategy for Building Wealth, Maximizing Tax Deductions, and Supporting a Beloved Charity

While most of us think of charitable giving around the holidays (or around tax time!), for many it is prudent to plan your giving to receive all of the benefits that are available to you. Planned giving comes in many forms...more

June Special Session?

Gov. Mark Dayton rejected a $259 million tax cut bill at midnight Tuesday by declining to sign it (pocket veto). The Omnibus Tax Bill would have delivered new credits, exemptions and deductions for farmers, businesses and...more

Massachusetts Court Issues 'True Debt' Decision

On June 8, the Massachusetts Appeals Court once again denied a taxpayer’s claimed deductions from the income and net worth tax base of the corporate excise tax. In a decision that will be a disappointment for taxpayers...more

Chameleon SROs: The Gov’t, But Not Really

For years, self-regulatory agencies (like FINRA or the Exchanges) have wielded the statutory authority granted them by Congress – and backed by the SEC – exercising governmental power to compel testimony, impose fines and...more

New York State Denies Taxpayer's Insurance (Deduction) Claim - Tax Update Volume 2016, Issue 1

Captive insurance arrangements, in New York and in certain other states, are often dependent on the federal treatment of the relationship as insurance for federal income tax purposes. A recent New York state...more

NC Legislative Update - June 2016

This Week - While the Senate was predominantly focused on the budget this week, the House moved forward with a number of high-profile issues. By a vote of 60-49, the House approved House Bill 1080, sponsored by Rep....more

Don’t Get Tripped Up By Hobby Loss Rules

The “hobby loss” rules of Internal Revenue Code Section 183 are commonly overlooked limitations that restrict the amount of loss a taxpayer may claim from an “activity not engaged in for profit” – i.e., a hobby. The...more

NC Legislative Update - May 2016 #3

Last Week - The House released its 150-page proposed budget adjustments for the 2016-17 half of the 2015-17 biennium on Monday evening and proceeded to work through the week in passing it. The proposal is relatively...more

While Some Parents May Not Agree to Pay the Cost of Their Child’s Law Degree, Maybe the Government Will?

Earlier this week, United States Tax Court Judge Richard T. Morrison ruled, in the case of Emmanuel A. Santos v. Commissioner, T.C. Memo 2016-100 (May 17, 2016), that the government will not pay the cost of a taxpayer...more

UK Financial Regulatory Developments - May 2016 #8

FCA announces insider dealing convictions - FCA has announced two convictions in the case it brought as part of Operation Tabernula. Martyn Dodgson, an investment banker, and Andrew Hind, a property developer and...more

Department of Revenue Issues Guidance Regarding the Act 52-2013 Add-Back Provision

On February 19, 2016, the Pennsylvania Department of Revenue (“Department”) released Information Notice Corporation Taxes 2016-1 (“Notice”) regarding the Act 52-2013 add-back provision that disallows corporate net income tax...more

NJ Tax Court Denies Interest Addback Exception - Does Your Company Still Qualify?

In a decision published April 26, 2016, the New Jersey Tax Court in Kraft Foods Global Inc. v. Director, Div. of Taxation ruled that a taxpayer couldn’t deduct interest paid to its corporate parent. The taxpayer’s...more

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

UK Financial Regulatory Developments - April 2016 #13

FCA finalises guidance on sharing SME credit information - FCA has published its finalised guidance on Small and Medium Sized Business (Credit Information) Regulations. This follows Treasury’s designation of the banks...more

Post-Death Action Reduced Amount of Estate Tax Charitable Deduction

Decedent died and left a majority stake in a real property management corporation to a private foundation. The estate tax value of the stock was $14.182M. After the decedent’s death, but before the stock was transferred...more

There Was a Panel on What?? Notes on the ABA Antitrust Spring Meeting Panel on Marijuana Law

Attendees at this year’s Spring Meeting may have been surprised by an unexpected panel: an overview of the status of the law related to the legalization of marijuana and antitrust issues facing the nascent industry. However,...more

Be Organized to Preserve Your Charitable Deductions for Property Donations

3 Things to Remember About Documenting Charitable Gifts of Property, Securities and Art. Last month in this blog, we described five ways to be diligent about documenting charitable gifts of cash or out-of-pocket expenses...more

Three Important Alabama Regulatory Developments

Last month, the ADOR proposed a new rule, Rule 810-3-35-.01, in order to simplify the federal income tax deduction available to corporations doing business in Alabama. The ADOR proposed to repeal the current corporate federal...more

Critical Tax Considerations When Structuring A Family Office

A wealthy family may create a family office to achieve a wide range of objectives. These objectives may include realizing the benefits of pooled capital in order to maximize the universe of available investment opportunities...more

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