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
Tax season is right around the corner for direct sellers. Are you prepared?
Consultants, have you kept track of your IRS tax deductions? Did you know that you can deduct such expenditures as meals, entertainment, home...more
Action by December 31st Required for Safe Harbor -
Yesterday, the IRS issued specific guidance on how employers can address issues arising from the change in tax treatment for same-sex spouses under cafeteria plans. ...more
IRS Explains Federal Tax Consequences of Windsor Case Regarding Same-Sex Marriages -
In our last report (Vol. 8, No. 3, September 2013), we told you about the recent Windsor case, in which the Supreme Court held...more
As a result of changes in North Carolina’s state income tax law, employees must complete a new Employee’s Withholding Allowance Certificate, Form NC-4 or Form NC-4EZ, so that employers can withhold the correct amount of North...more
When an employer requires an employee to move his or her primary residence to work, or continue working, for the employer, oftentimes the employer, as an inducement for the employee to accept the offer employment or continue...more
The inflation adjustments for tax items for tax year 2014 of greatest interest to most taxpayers include the following dollar amounts....more
Year-end tax planning could be especially productive this year because timely action could nail down tax breaks that won’t be around next year unless Congress acts to extend them, which at the present time, looks doubtful....more
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