Tax Exemptions

News & Analysis as of

Holding Assets in Trust for the Next Generation

Over the past few years, we have seen a dramatic increase in the number of clients interested in holding assets in trust for their children. This is a trend we are noticing across the board, regardless of the size of the...more

IRS Issues New Management Agreement Safe Harbor Provisions, Providing Enhanced Flexibility for College and University Food...

New management agreement guidelines were issued by the IRS today in a new Revenue Procedure (Rev. Proc.) 2016-44. Rev_Proc_2016-44 provides revised safe harbors under which a private management contract does not result in...more

Government Set to Overhaul Taxation on Termination Payments

Currently, non-contractual compensation payments made solely on account of termination of an individual’s employment enjoy a favourable tax treatment in two respects – the payment can be made without deduction of income tax...more

Changes to tax treatment of termination payments

The UK Government has announced changes to the tax treatment of termination payments following the conclusion of its recent consultation. Draft legislation has now been published which will come into force in April 2018....more

D.C. Circuit Court Gives Victory to Conservative Non-Profit Groups Targeted by IRS

Last week, the U.S. Court of Appeals for the D.C. Circuit reversed two district court decisions that had dismissed the claims of dozens of conservative non-profit organizations (the "Plaintiffs") in the Internal Revenue...more

Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights [Video]

Sutherland SALT tracks and tallies significant state and local tax litigation wins and losses in the quarterly Sutherland SALT Scoreboard publication. In this videocast, Charles C. Capouet and Elizabeth S. Cha share the...more

California Health Care District Financing Techniques

Across the nation, the delivery of health care services is undergoing a period of transformation. Much of this change is being driven by The Affordable Care Act signed into law in 2010. Many hospital facilities in...more

Insight on Estate Planning - August/September 2016

In This Issue: - Alternate valuation date: Flexible postmortem planning a plus when markets are volatile - The write stuff: A letter of instructions - Making the most of your GST tax exemption - Estate...more

Portability: A Useful Estate Planning Tool

The concept of "portability" in estate planning is the most substantial change to the estate planning landscape for married couples in recent memory. Introduced as a temporary feature by the 2010 Tax Relief Act, portability...more

The Economic Development Toolbox: Downtown Redevelopment Districts Provide Additional Economic Development Tools for Ohio...

On May 6, 2016, Governor Kasich signed Am. Sub. House Bill 233 (“H.B. 233”) authorizing Ohio municipalities to create Downtown Redevelopment Districts (“DRDs”) to encourage the rehabilitation of historic buildings and...more

Sales Tax Exemption for Manufacturing Held Inapplicable for Oil and Gas Equipment, but Questions Remain

Southwest Royalties, Inc. v. Hegar, No. 14-0743 (Tex. June 17, 2016)(“Southwest”), addresses the applicability of a sales tax exemption for property sold for use in manufacturing in the context of oil and gas production....more

IRS Denial of Accountable Care Organizations Raises More Questions Than It Answers

In a recent ruling, PLR 201615022, the IRS denied tax exemption to an accountable care organization on the basis that the organization was conferring private benefit on its participating physicians by negotiating shared...more

Under the Dome: Inside the Maine State House

Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. Maine Senate Will Reconvene August 4 to Consider LePage Nominations - Governor Paul LePage has...more

Reserved Alternative Investment Funds A revolutionary solution for alternative investment funds in Luxembourg

The Luxembourg alternative investment fund environment has been significantly improved on the 14 of July 2016 with the adoption of the law on Reserved Alternative Investment Funds (RAIF)....more

Spotlight on Tennessee: R&D Exemption for Sales/Use Taxes

This State's industrial machinery exemption for sales and use tax purposes offers a significant benefit to manufacturers in Tennessee. With a general State tax rate of 7%, together with the added local tax rates, substantial...more

Proposed Rule Changes to Florida’s Affordable Housing Allocation and Funding Process

The Florida Housing Finance Corporation (“Florida Housing”) has proposed changes to its rules governing the affordable housing allocation and funding process. The changes are to Rule Chapters 67-21, 67-48, and 67-60, F.A.C....more

Financial Services Quarterly Report - Second Quarter 2016: The Société de Libre Partenariat: A New French Fund Alternative

The implementation of the AIFM Directive has afforded the French legislature the opportunity to simplify its range of regulated investment vehicles, with the aim of making France’s financial markets more attractive – both to...more

IRS Announces Major Qualified Plan Determination Letter Program Change

The Internal Revenue Service has published very important new guidance on assuring employer sponsored pension and profit sharing plans qualify for tax exemption. Revenue Procedure 201637, 2016-29 Internal Revenue Bulletin,...more

Proposed 409A Regulations Provide Clarity and Some Flexibility

On the same day it released proposed regulations under Section 457 — as reported in our "New 457 Regulations for Nonqualified Deferred Compensation Plans of Tax-Exempt and Government Employers" update —the IRS released...more

Senator Warren Leads Coalition to Expand Scope of Limitations on Executive Compensation Tax Deductions

Section 162(m) of the Internal Revenue Code generally limits the deductibility of compensation paid in excess of $1 million to the chief executive officer and the three other highest compensated officers (other than the chief...more

"Recent Developments in the Use of Variable Interest Entities"

The variable interest entity (VIE) structure has been around since the listing of Sina.com on the Nasdaq Stock Market in 2000. It enables companies to exercise control over operating entities and derive economic benefits from...more

IRS Issues Proposed Regulations Under Code Section 457

On June 21, 2016, the Internal Revenue Service (IRS) issued long-awaited proposed Treasury Regulations prescribing rules under Section 457 of the Internal Revenue Code (the "Code") for the income taxation of deferred...more

The ERISA Litigation Newsletter - June 2016

Editor's Overview - In this month’s newsletter, our colleagues focus on two sets of legislative updates. First is a discussion of the IRS’s proposed Treasury Regulations prescribing rules under Section 457 of the...more

Texas Comptroller Prevails in Tax Exemption Claim

A fight over the Texas sales tax drew industry-wide attention when the trial judge commented from the bench that he was inclined to exempt purchases of casing, tubing, pumps and related services from Texas state sales tax....more

EU Council Agrees on Final Anti Tax Avoidance Directive

We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more

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