News & Analysis as of

Tax Deferral

China implements new tax and administrative measures to boost foreign investment

by DLA Piper on

The Standing Committee of the China State Council, in their meeting of 28 July, released a strong signal on the encouragement of foreign investment in China. The meeting resulted in several particular measures aiming to...more

Deferring Taxes but Keeping the Cash

by Slim Ventures LLC on

In recent years, many public and private companies have been able to defer capital gains tax on appreciated assets while keeping up to 95% of the proceeds (versus 65%-75% in paying taxes). ...more

Trump Tax Proposal Could Create Compensation-Related Opportunities

The Trump administration’s proposed overhaul of the federal income tax system includes a reduction of the maximum federal corporate income tax rate from 35 percent to 15 percent. If enacted, the proposal — a one-page outline...more

Donating Fund Interests: A “Why Now?” and “How To” Primer

Due to increased valuation of public and private equities, coupled with the upcoming end of the sunset provision that allows hedge fund managers to defer taxation on fees earned offshore, there is an increased interest among...more

Preserving Deferred Tax Assets in a Capital Raise

by Bryan Cave on

Hosts Jonathan Hightower and Rob Klingler discuss recent capital raises and techniques used to preserve deferred tax assets....more

“Tax-Free” Exchanges May Not Be Free of Tax

by Farrell Fritz, P.C. on

Business owners love to hear the words “tax-free” when considering the disposition of business assets. Unfortunately, many fail to grasp that a tax-free disposition is rarely free of tax in the sense of never being taxed;...more

Is a charitable IRA rollover a viable option?

For those age 70½ or older who plan to make charitable donations this year, qualified charitable distributions from an IRA, also known as charitable IRA rollovers, can provide significant tax benefits. This article details...more

Protecting Tax Deferral for A Contribution to A Partnership

by Farrell Fritz, P.C. on

When a taxpayer (“Taxpayer”) sells a property (“Property”) with a fair market value (“FMV”) in excess of Taxpayer’s basis in Property in exchange for cash in an arm’s-length transaction, the amount of gain that he realizes on...more

Pending Alabama Tax Legislation (2017 Regular Session) State and Local Tax Alert: Alabama Edition

The House and Senate have each met a total of six legislative days thus far. There are therefore 24 legislative days remaining in the 2017 Regular Session. The House will reconvene on Tuesday, February 28 at 1:00 p.m. The...more

Stretch out estate tax on business interests

Frequently, heirs of successful entrepreneurs are forced to sell off business interests at “fire sale” prices to help pay federal estate taxes. To alleviate the tax strain, Internal Revenue Code Section 6166 allows heirs to...more

Employee Benefits Legislation Proposed (But Not Passed) by the Obama Administration

by Jackson Walker on

In February of 2015, the Department of Treasury issued a reported entitled “General Explanation of the Administration’s Fiscal Year 2016 Revenue Proposals” (the “General Explanation”). The General Explanation is several...more

Rollover Equity in the Sale of a Family-Owned Business

If you sell your family-owned business to a private equity buyer, the buyer will most likely pay a portion of the purchase price with equity in the buyer’s new company, rather than with cash. The equity that you receive in...more

West Coast Real Estate Update: November 2016 #3

by Holland & Knight LLP on

Owners, Developers Face Challenges Converting Parking to E-Commerce Delivery Space - Because millennials make up an increasing number of urban residents, owners and developers of apartment and condominium buildings are...more

Treasury Targets Tax Deferral in Leveraged Partnership Structures with New Regulations

by Goodwin on

The Treasury issued new final, temporary and proposed regulations that take aim at, and significantly reduce the effectiveness of, leveraged partnership structures intended to achieve tax deferral to the contributing partner....more

Introduction of the Empowering Employees through Stock Ownership (EESO) Act

On July 12, 2016, the Empowering Employees through Stock Ownership (EESO) Act (S. 3152) was introduced to the U.S. Senate by Sens. Mark R. Warner (D-VA) and Dean Heller (R-NV). The Act is intended to make it easier for...more

Advantages of Using ESOPs To Structure Acquisitions and Divestitures In An Uncertain Economy

by McDermott Will & Emery on

M&A advisors are becoming increasingly familiar with leveraged ESOP transactions and are routinely considering the ESOP platform in structuring acquisitions and divestitures. The first part of this article references the...more

New bill on Luxembourg 2017 Tax Reform - On 26 July, 2016 the Luxembourg Government presented to Parliament bill of law n°7020,...

by Dentons on

Bill of law n°7020 amends and confirms the new tax measures previously announced: 1. Corporate income tax (CIT) 1.1 Introduction of a 17 year limitation on the use of tax losses as from 2017 The limitation will...more

New Amendments to Pennsylvania’s Unclaimed Property Law (2016)

by K&L Gates LLP on

Significant changes affecting all holders of unclaimed property were included in amendments to Pennsylvania’s Fiscal Code adopted as part of the state’s 2016-17 budget. The amendments establish requirements for the...more

The Legacy of Michigan Senator Levin and Offshore Taxation Issues

by Michael Volkov on

When Senator Levin, the Democrat from Michigan, announced his retirement from the Senate in 2014, you could hear a collective sigh of relief from the corporate business community. Senator Levin had dedicated himself to...more

Federal Tax Advisory: General Utilities Repeal and Spins

by Alston & Bird on

Notice 2015-59, 2015-40 IRB 459, issued last September, suggests that the IRS has concerns about several aspects of Section 355 tax-deferred spinoffs. One of these is the relevance of the 1986 repeal of the General Utilities...more

President Obama’s Administration Continues Its Quest to Limit the Ability to Defer Income Under IRC § 1031

by Garvey Schubert Barer on

As reported in my November 2014 blog post, President Obama’s administration wants to limit taxpayers’ ability to defer income under IRC § 1031. In response to former House Ways and Means Committee Chairman David Camp’s...more

Obligation to Perform Work and Incur Costs Under Construction Contract is a Section 752 Liability

by Miles & Stockbridge P.C. on

In a recently issued Private Letter Ruling (PLR 201608001), the IRS determined that a taxpayer-partnership’s obligation to perform work and incur costs under a long-term construction contract constituted a partnership...more

Group Seeks Relief For U.S. Citizens With RESP and TFSA Accounts

by Hodgson Russ LLP on

In a letter dated March 4, 2016, the American Chamber of Commerce in Canada (“AmCham Canada”) requested that the United States Department of the Treasury (“Treasury”) provide various forms of tax relief to U.S. and Canadian...more

A Quick Refresher on the Tax Consequences of Condemnation

by Nossaman LLP on

Most of us are at least vaguely familiar with the tax on gains from the sale of property. Many of us know that when property is sold voluntarily and the funds re-invested, the gain may be deferred under Internal Revenue Code...more

IRS Announces Intent to Tax Transfers to Partnerships

On August 6, 2015, the IRS issued Notice 2015-54 (the "Notice"),[1] which states that the IRS and Treasury Department intend to issue regulations under section 721(c) of the Internal Revenue Code of 1986 (the "Code") to...more

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