Tax Exemptions

News & Analysis as of

The 5% Solution: IRS Revenue Procedure 2016-42 Provides Relief for the Probability of Exhaustion Test

Charitable Remainder Annuity Trusts (CRATs) can be a very effective charitable planning tool. Choosing to fund a CRAT can remove assets from the estate of the donor, provide a reliable income stream for a family member and...more

The Repeal of the New Jersey Estate Tax: Is it Now Safe to Move Back to New Jersey?

On October 14, 2016, Governor Christie signed into law a transportation funding bill that also included the repeal of the New Jersey Estate Tax. Here is what you need to know: - The New Jersey Estate Tax repeal will be...more

Minimizing Federal Income Tax on Sale of Qualified Small Business Stock

A taxpayer who is considering the sale of certain stock may have the opportunity to exclude or defer part or all of the gain on such sale. To be eligible for the exclusion or deferral, such stock must be “qualified small...more

SCOTUS Asked to Hear Appeal Involving Constitutionality of Retroactive Tax Legislation

The Supreme Court of the United States has been asked to hear an appeal in a case involving the circumstances in which retroactive tax legislation will be constitutional. In Dot Foods, Inc. v. State of Washington...more

Changes to the principal residence exemption

On October 3, 2016, the Minister of Finance of Canada announced changes to the federal Income Tax Act that will affect the availability of the principal residence exemption to non-residents and those who hold their principal...more

New Jersey Phases in Full Estate Tax Repeal

On October 7, 2016, the New Jersey Legislature adopted a comprehensive tax package with important tax cuts, including an end to the estate tax by 2018. Specifically, the legislation provides the following: - The...more

U.S.-India Newsletter - Vol. 2016, Issue 3

Summer 2016 was a season of change. In Europe, we saw the "Brexit," with the United Kingdom voting to withdraw from the European Union. The June referendum sent shockwaves through the business and finance communities and...more

Recent Changes to the India-Mauritius Tax Treaty: What Does This Mean for American Investors?

The amendments may cause some uncertainty and anxiety for U.S. investors as they consider how these changes will impact business, income, profitability and the benefits or drawbacks of investing in India through Mauritius....more

Updated Historical Transfer Tax Rates & Exemptions

Please see chart below for more information....more

Nashville Islamic Center Claims Tax Rules Impose Unfair Burden

The Islamic Center of Nashville (ICN) recently filed a federal complaint and request for declaratory judgment against the State of Tennessee, the Metropolitan Trustee of Nashville, and the Tennessee State Board of...more

Massachusetts Outlook: The Remainder of 2016 and Beyond

After closing the book on the formal sessions in July, Massachusetts lawmakers have turned their attention to the November election. The Senate and House of Representatives convene in informal sessions for the remainder of...more

Employee Benefits Developments - September 2016

Final IRS Regulations Eliminate Requirement to File 83(b) Election with Tax Return - Under Section 83(a) of the Internal Revenue Code (the “Code”), if property is transferred in connection with the performance of...more

Insight on Estate Planning - October/November 2016

Gift giving made easy - Annual exclusion reduces your taxable estate - How can you reduce the size of your taxable estate? There are many ways to accomplish this objective, including the use of irrevocable trusts...more

Mining in the Kingdom of Saudi Arabia — An Overview

Sector Profile - Covering two million square km, the Kingdom of Saudi Arabia is the largest country by landmass in the Middle East and the 13th largest in the world. The Kingdom’s geology gives it an abundance of natural...more

Third Circuit Deals Blow to Jersey City Ordinance Requiring PLAs on Privately Funded Projects in Exchange for Tax Abatements

Jersey City’s Municipal Code offers real estate developers generous tax exemptions that are designed to spur the City’s economic growth, but the tax incentives have strings attached. Specifically, to receive a tax exemption,...more

Projected Inflation-Adjusted Estate, Gift and GST Tax Exclusion Amounts for 2017 Now Available

Based on the Consumer Price Index for the 12-month period ending August 31, 2016, Thompson Reuters Checkpoint has released their projected inflation-adjusted Estate, Gift, GST tax, and other exclusion amounts for 2017, as...more

Offshore Companies in the UAE

Whether there is a need to restructure a business, to protect assets or simply develop an international presence for a business, one of the ways of doing so, is by opening an Offshore company....more

IRS Continues Trend of Flexibility for Qualified Management Agreements (QMA’s) for Hotels Financed With Tax Exempt Bonds

The US Internal Revenue Service (IRS) recently continued a trend of pronouncements further extending flexibility in structuring a Qualified Management Agreement (QMA) for a hotel financed with tax exempt bonds without...more

California Ballot 2016: Pros and Cons of Props 62-67

This is part three of our ongoing series, California Ballot 2016, summarizing each of the 17 state-wide measures voters will encounter on the November ballot. Click these links: Props 51-56, or Props 57-61 to catch up on the...more

House Tax Policy Review Committee Update - Public Policy Alert from the South Carolina State House

The House Tax Policy Review Committee held its second meeting on Tuesday, September 13th, to discuss income and sales tax issues and statistics. Gordon Shuford with the South Carolina Revenue and Fiscal Affairs Office made a...more

Florida Open for Captive Insurance Business

After several decades, Florida is back in the business of licensing captive insurance companies. On Aug. 11, 2016, the Florida Office of Insurance Regulation issued a license to a nonprofit Florida corporation, pursuant to...more

Clinton and Trump Propose Diametrically Opposed Tax Plans

The tax plans proposed by the candidates are perhaps the most conventional element in an unconventional election year as both plans hew closely to their parties' proposals. In the broadest sense, Secretary Clinton's tax plan,...more

Put Me in Coach! Using Split Dollar Life Insurance Plans to Compensate Division I Coaches

In August 2016, the national sports media provided details regarding the compensation package for Coach Jim Harbaugh at the University of Michigan. It comes as no surprise to anyone that Division I football and basketball...more

The next chapter - A new bond linking financial returns to environmental or social goals could thrive. But securities law...

Shakespeare’s Juliet may not have ascribed great significance to a name but for securities lawyers and market participants alike there is significance to nomenclature. Social impact bonds, or investments that are intended to...more

Alabama Legislature Signals Reexamination of Tax Incentives and Exemptions: State and Local Tax Alert: Alabama Edition

Following a contentious special session in which multiple proposals for a state-wide lottery were debated then abandoned, the Alabama Legislature adjourned on September 7 after approving an approximate $640 million bond issue...more

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