Tax Deductions

News & Analysis as of

How Is a Relator’s Recovery in an FCA Settlement Taxed?

This rarely litigated question was presented to the Seventh Circuit in Patrick v. Commissioner of Internal Revenue, No. 14-2190, 2015 WL 5024985, — F.3d —- (Aug. 26, 2015). Previously, the First Circuit, in Fresenius Medical...more

Tax Changes Included in the Trade Preferences Extension Act of 2015

The recently enacted Trade Preferences Extension Act of 2015 (the "Act") contains a number of tax provisions affecting businesses and individuals which have not been widely reported. The Act adds a requirement for claiming...more

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

Tax Newsletter - May/June 2015 (China & Hong Kong)

The tax arena in both China and Hong Kong has been a buzz since the last issue of our Tax Newsletter. In this edition, we draw your attention to certain recent developments that may carry legal and tax implications for your...more

Tax and Estate Planning Newsletter - Summer 2015

Dear Clients and Colleagues: This summer’s weather is a mix of hot and cold temperatures, and the rain we need so desperately is coming now in sprinkles along with thunder and lightning. Along with changes in the...more

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

On-Line Fundraising, Some Tax Implications

Many have participated in, or know someone who has launched, a “Kickstarter” campaign or other online means of securing funds for a project. Others may have encountered a request for contributions to a “fund” for some tragic...more

The ABLE account: A good alternative to a special needs trust?

Late last year, Congress passed, and the President signed, the Achieving a Better Life Experience (ABLE) Act. The act authorizes a new, tax-advantaged savings account, modeled after the Section 529 college savings account,...more

FINRA Warns on Muni Shorts & Fails: Substitute Interest is Taxable

FINRA issued its late-July Regulatory Notice 15-27 warning brokerage firms that inadvertent short positions or fail-to-delivers in municipal securities trading can create situations where the member-firm pays a customer...more

Tax Proposals to Eliminate Interest Deductions Miss the Mark

The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies. In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more

Lessons Learned in Conservation Partnerships

The Internal Revenue Code has provided an incentive under Section 170(h) for charitable conservation gifts. Since at least 2002 there has been an interest in combining through partnership those land owners who may have little...more

UK Summer Budget 2015 – Key Issues for Asset Managers and Non-UK Domiciled Individuals

On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership),...more

Living at the Casino Does Not Make You a Professional Gambler

Professional gamblers can offset their losses from gambling against their gambling winnings. They can also deduct their other gambling expenses. Non-professionals (those not engaged in the trade or business of gambling) are...more

Guide To Doing Business in New Zealand: Taxation (Updated)

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

State Legal Marijuana Dispensaries Lose Out on Business Deductions

Federal income tax is a tax on “net” income – gross income less allowable deductions. Unless, however, you are a drug dealer – Code Section 280E does not allow sellers of federally controlled substances to deduct their...more

IRS v. Medical Marijuana: IRS 1 Medical Marijuana 0

The Internal Revenue Code may be the single strongest enforcement weapon in the battle over legal sale and distribution of "medical marijuana". The Opinion of the United States Court of Appeals for the Ninth Circuit, Oliver...more

U.S. Supreme Court Holds Same-Sex Marriage To Be a Fundamental Right

The United States Supreme Court issued its opinion in Obergefell v. Hodges, 576 U.S. ___ (2015) on June 26, 2015. In a 5-4 decision, the Supreme Court held that the Fourteenth Amendment requires a State to license a marriage...more

Pennsylvania’s NOL Cap Litigation Moving Forward

In a Corporate Net Income Tax (“CNI”) appeal filed by Nextel Communications of the Mid-Atlantic, Inc. (“Nextel”), the Commonwealth Court will consider whether Pennsylvania’s statutory cap on net operating loss (“NOL”)...more

Advertising Law - June 2015 #4

In Case You Missed It: FCC Adopts Significant Changes to TCPA Rules - Last week, in TCPA Connect, our newsletter devoted to cases and developments surrounding the Telephone Consumer Protection Act, we reported on the...more

Stretched for Resources, the IRS Sets Its Sights on Small Captive Insurers

A "captive" insurance company is an insurer formed for the limited purpose of insuring the risks of its non-insurer owner or owners. A captive can be an effective risk-management tool, especially for costly or unconventional...more

New Maine Budget Would Make Numerous Tax Changes

Hoping to avoid a potential government shutdown, this week the Legislature passed a biennial budget that once again makes significant tax changes, but stops well short of the major tax reform desired by many legislators. The...more

Focus on Tax Controversy and Litigation - Supreme Court Decides Maryland v. Wynne and Rules that Maryland Tax Scheme Is...

In This Issue: - Maryland’s Tax Scheme Ruled Unconstitutional - “FTC Generator” Case Update - FSA Rules that Equitable Disgorgement May be Deductible Expense - District Court Upholds Attorney Client...more

Wealth Management Update - June 2015

June Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The June § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

IRS Informally Rules Disgorgement Payments Under FDA Consent Decree May Be Deductible

In Internal Revenue Service Field Attorney Advice released May 22, 2015 (FAA 20152103F), the IRS Office of Chief Counsel expressed its informal view that the evidence suggests that the amount the taxpayer paid the United...more

Final Regulations on Section 162(m) Deduction Limit Exceptions

New final regulations(the “Final Regulations”) have been issued clarifying and altering the “qualified performance-based compensation” exception and the transitional “reliance period” exception for newly public companies to...more

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