This article describes how the new additional Medicare tax, tax on net investment income, higher marginal tax rates, and phase-out and reductions of personal exemptions and itemized deductions make the use of compensation...more
Captive insurance companies may now be domiciled in Texas under a law signed by Gov. Rick Perry on Monday. Texas joins more than 30 other states that permit the formation and operation of various types of captive insurance...more
As the Pennsylvania General Assembly heads down the home stretch to the June 30th deadline for passage of a budget for 2013-14, all indications suggest that the budget package will include significant substantive and...more
In a taxpayer-favorable decision earlier this month, the US District Court for the District of Massachusetts, following a jury verdict, entered judgment for a corporation in a tax refund suit permitting a business deduction...more
The White House recently released its Fiscal Year 2014 budget proposal, and there are many suggested changes that will impact individuals, businesses, and estates. Several of these proposals—particularly on the estate and...more
In a ruling handed down May 6, 2013, the Federal Court of Appeal ordered that portions of a Crown pleading be struck out for suggesting that a deduction may be disallowed on the basis that the conduct of the taxpayer in...more
Industry Outlines Impact of Government Interference - Earlier this year, we provided a summary of the Productivity Commission's review of non-financial barriers to exploration investment – please see the following...more
On April 10, 2013, the White House released its Fiscal Year 2014 Budget (the Budget), which includes a number of proposals related to employee benefit plans. Although it is unlikely that all of the proposals will ultimately...more
On April 1, 2013, the Internal Revenue Service (“IRS”) published proposed regulations clarifying the $500,000 deduction limit for compensation provided by certain health insurance providers, which is contained in section...more
Since the passage of The American Taxpayer Relief Act of 2012 and the submission of the President's federal budget proposal for 2014, it is clear that high net worth and high income taxpayers continue to be under attack....more
On April 10, the Treasury Department released its “General Explanations of the Administration’s Fiscal Year 2014 Revenue Proposals.” Known as the “Green Book,” the document provides an explanation of the Administration’s FY...more
On April 10, the Obama Administration released its fiscal year 2014 budget (FY 2014 Budget). Of note, the FY 2014 Budget includes a number of tax proposals that target insurance companies or that otherwise would have a direct...more
A couple going through a divorce action should understand whether a support payment, not specifically allocated as child support or alimony, is a taxable event where the payor may deduct it and the payee report it as income...more
On April 1, 2013, the Internal Revenue Service issued proposed regulations providing guidance on the $500,000 deduction limit for compensation paid by certain health insurance companies to their employees. Because of the...more
In a recently released Chief Counsel Advice, the IRS National Office concluded that a publisher’s activities in producing an “electronic” version of books that were “printed” by a third party did not constitute qualifying...more
Earlier this year, the United States District Court for the Middle District of Louisiana upheld the Internal Revenue Service’s disallowance of $1 billion of deductions claimed by Dow Chemical in relation to two transactions...more
Many couples hesitate to end their marriage for a variety of reasons – most of which are financial. So it may come as a surprise to couples who have reached the conclusion that it is time to end their marriage that they may...more
To insulate the ultimate individual owners from U.S. estate taxes, nonresident aliens often hold U.S. real property in a U.S. corporation, which corporation is owned by a foreign corporation. The foreign corporation is owned...more
April 15th is just around the corner, and every year clients ask us what paperwork is needed to document charitable contributions. As a reminder, the IRS allows you to deduct up to 50% of your adjusted gross income donated...more
Budget 2013 was tabled on March 21, 2013. Heenan Blaikie’s National Tax Group has prepared the following overview of some of the more significant tax-related measures....more
In This Issue: - Business Torts in Virginia - Virginia Non-Competition Law After Home Paramount - 2013 Mileage Rates Alert - Excerpt from 2013 Mileage Rates Alert: The Internal Revenue Service has...more
Code §465 limits deductions for taxpayers in business and investment activities to the amount the taxpayer has "at risk" in the venture. Amounts of owners that are contributed to capital are generally at risk. Also at risk...more
Tax issues are among the many legal challenges same-sex and non-traditional couples face. Currently the Defense of Marriage Act of 1996 (DOMA) requires that under federal law marriage is between a man and a woman. Our federal...more
As we have previously reported, despite the growing number of States (18 in total) that have sanctioned the use of marijuana in various forms, the federal government has continued its efforts to crack down on dispensaries....more
Cash basis taxpayers may deduct “qualified residence interest” when paid. Qualified resident interest is generally interest on a loan taken out to purchase a qualified residence, or to refinance it within certain dollar...more
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