On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable created to implement a transfer pricing adjustment did not constitute...more
On 9 March 2015 Federal Law No. 32-FZ “On Amending Part II of the Tax Code of the Russian Federation”, dated 8 March 2015, entered into force.
The Law is aimed at softening the negative tax effect on borrowings resulting...more
Planning on making a large gift to charity? Rather than making a gift outright, it might beneficial to consult an attorney and set up a charitable remainder trust, an instrument that allows you to donate to charity while...more
Estates and trusts with charitable beneficiaries often seek to employ the Code Section 642(c) charitable set aside deduction for income earned by the estate and trust that will eventually (but not in the current tax year) be...more
Late last year, Congress approved nearly $11 billion to fund the Internal Revenue Service for fiscal year 2015 – the lowest allotted amount since 2008, according to CNN Money. As a result, the IRS announced delays in...more
Valentine’s Day is a great time to count your blessings and make good on your charitable intentions. Why not provide for your loved ones while also providing for a charity that is near and dear to your heart? Clients with an...more
Every year for the past several years, Congress has passed a series of what are referred to as "tax extenders" - reinstatements of tax deductions and credits that have expired before the current tax year. It did so again in...more
Wondering if your favorite individual “tax break” was extended by Congress on December 16, 2014? This article sheds some light on that question....more
In 1980, when extending the business and occupation (B&O) tax to financial institutions, the legislature provided a deduction for “amounts derived from interest received on investments or loans primarily secured by first...more
When we think about our personal residence, we probably do not give much thought to the tax impact associated with it. If we do think about the tax aspect, our focus probably is on the savings related to the mortgage interest...more
In a recent Chief Council Advice, the IRS summarizes and reaffirms various principles that can be applied to determine who gets an interest deduction for payments made on a home mortgage when there is more than obligor under...more
The Tax Court of Canada again confirmed that directors of corporations will have a high burden to meet to establish a due diligence defence and avoid liability for unremitted source deductions....more
Earlier this year, we advised employers that the Bay Area Commuter Benefits Program (“CBP”) was going into effect, beginning September 30, 2014. (Govt. Code §65081.) This post provides additional information on the...more
As a general rule, interest paid by individuals is not tax deductible. A principal exception to the general rule allows a deduction for “qualified residence interest,” i.e., interest with respect to indebtedness incurred in...more
I previously posted about the increase in retirement plan contribution limits for 2015. This week the IRS announced the tax brackets, personal exemption, and standard deduction amounts for tax year 2015. To be clear, the new...more
All too often, people don’t keep adequate records to demonstrate they are entitled to deduct travel expenses.
The general rule from the Supreme Court is that deductions are a matter of legislative grace, and taxpayers...more
In Maddin v. The Queen (2014 TCC 277), the taxpayer was a director of a corporation in the marble and granite industry (the “Corporation”) which failed to remit nearly $300,000 of source deductions related to salaries, wages...more
As of October 17, 2014, expenses incurred abroad on a prorated basis with parties that are not income tax payers in Mexico will be fully deductible to the extent certain requirements are met. The foregoing is pursuant to a...more
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
Are you considering making a significant charitable legacy gift? What type of vehicle should you use? Donors often have similar goals in mind — helping a charity dear to their heart and saving on taxes. However, donors may...more
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