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
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
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
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
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
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
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
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 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
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
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
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
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
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
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
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
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
House Ways and Means Committee Chairman Dave Camp (R-Michigan) this week introduced a draft of the most comprehensive reform of the Internal Revenue Code in decades.
The key principles in the draft are:
On February 4, the IRS issued a new revenue ruling – Rev. Rul. 2014-7 – that indicates that the IRS no longer plans to issue formal guidance concerning the treatment of the dividends-received deduction (DRD) with respect to...more
A taxpayer who travels away from his tax home overnight on business can deduct 50% of meals and 100% of lodging costs. A taxpayer’s “tax home” is located at (1) his regular or principal (if more than one regular) place of...more
Charitable contributions are only deductible if you itemize and have the proper substantiation.
For cash contributions of less than $250, you must have either a cancelled check/credit card receipt or a written...more
Same-sex marriages now are being recognized under federal tax law for the first time. In June 2013, the Supreme Court released its decision in United States v. Windsor, 530 U.S. 12 (2013), declaring Section 3 of the federal...more
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