Tax Exemptions

News & Analysis as of

Hong Kong Government to Extend Existing Offshore Funds Tax Exemption to Private Equity Funds

The Hong Kong government has announced in its latest budget a planned extension of the existing offshore funds tax exemption to bring offshore private equity funds investing in or through Hong Kong, within its scope. The...more

Philadelphia Tax Exempt Property Owners Must Reapply for Exemption by March 31, 2015

The Philadelphia Office of Property Assessment (OPA) has begun mailing notices to each owner of property listed as tax exempt on the OPA’s records indicating that the owner must file a form to certify that the property...more

Indiana Tax Court rejects property tax exemption for Homeowners’ Association that failed to show it was organized to retain and...

A Hoosier Homeowners’ Association was denied a property tax exemption because it failed to show that it was established for the purpose of retaining and preserving its land and water for their natural characteristics....more

Owners of Tax-Exempt Property in Philadelphia Must Provide Proof of Right to Continued Tax-Exempt Status

The Philadelphia Office of Property Assessment (OPA) has sent letters to all charitable organizations in the city that own property shown as tax-exempt, in whole or in part, in the OPA’s records. Attached to the letter is a...more

Is a Distribution of Previously Taxed Income “Exempt from Tax”?

A U.S. shareholder of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of the CFC’s subpart F income and/or the amount determined under Section 956 with respect to such...more

A Deluge Of Dismissals: Indiana Tax Court Dismisses 11 Property Tax Exemption Appeals For Lack Of Jurisdiction

When it rains, it pours. On January 20, the Indiana Tax Court issued eleven rulings dismissing property tax exemption appeals for lack of jurisdiction....more

The Seventh Circuit Interprets Wisconsin Exemption Law on College Savings Accounts and Retirement Annuities, but Did It Have...

As we explained in a post yesterday, the Seventh Circuit in In re Bronk (Cirilli v. Bronk), No. 13-1123 (7th Cir. Jan. 5, 2015), made some new law on Wisconsin’s college savings account (Edvest) and annuity exemptions for...more

New This Month: MO Supreme Court Limits the Construction Industry's Use of Certain Sales and Use Tax Exemptions

On January 13, 2015, the Missouri Supreme Court issued three decisions on sales and use tax that have limited the construction industry's ability to utilize certain exemptions in those areas. Companies that utilize such...more

Who is “Disabled” under ABLE?

The recently-enacted federal ABLE statute provides a long-awaited vehicle for tax-exempt investing to meet future disability-related expenses of disabled individuals. Although new Section 529A of the Internal Revenue Code is...more

Electricity Transmission and Distribution Equipment Ineligible for Georgia Sales Tax Manufacturing Exemption

The Georgia Tax Tribunal has held that an electric utility’s transmission and distribution equipment was not “necessary and integral to the manufacture of tangible personal property” and thus did not qualify for an exemption...more

Enactment Imminent for Section 529A Tax-Exempt Savings Programs for Disabled Beneficiaries

On December 16, 2014 the U.S. Senate approved the Achieving a Better Life Experience (“ABLE”) legislation previously approved by the House, authorizing state-sponsored tax-exempt savings programs for disability-related...more

The Economic Development Toolbox: “The Clean-Up Hitters” – Enterprise Zone and Community Reinvestment Area Property Tax Exemptions

Capital investment projects often involve tight margins, and every single dollar counts to ensure that the project is a success. For that reason, property tax exemptions are key components of any economic development...more

A new UK withholding tax exemption for privately placed debt

The Chancellor of the UK Exchequer, George Osborne, announced in the 2014 Autumn Statement on Wednesday a new targeted exemption from UK withholding tax for interest on qualifying privately placed debt. The exemption is a...more

Recent PA Sales Tax Guidance Concerning Natural Gas and Other Mining Activities

With all of the natural gas mining activity in Pennsylvania, the Department of Revenue has issued various guidance on what machinery, equipment and supplies falls within the "mining" exemption under Pennsylvania's sales and...more

Pennsylvania Tax Developments - A Reed Smith Quarterly Update: November 2014

This is a brief update on recent Pennsylvania tax developments. Does New Governor Mean More Tax Reform? In the recent gubernatorial election, challenger Tom Wolf (D) defeated incumbent Governor Tom Corbett (R)....more

Seventh Circuit: Plaintiffs Lacked Standing to Challenge Tax Exemption for Ministerial Rental Allowances

In November 2013, the U.S. District Court for the Western District of Wisconsin declared unconstitutional Section 107(2) of the Internal Revenue Code, which excludes from gross income rental allowances paid to ministers as...more

High Court Affirms Theater, Church’s Entitlement to State’s “Mandatory” Property Tax Exemption

The Court of Appeals, New York’s highest court, recently published decisions in the Maetreum of Cybele v. McCoy and Merry-Go-Round Playhouse, Inc. v. Auburn cases. In these decisions, the Court affirmed that the exemptions...more

Freedom From Religion Foundation: 7th Circuit Reminds That Standing Is Every Plaintiff's Cross to Bear

There is something to be said for not paying your taxes. At least, that is one lesson that the plaintiffs may have learned from the Seventh Circuit’s opinion last Thursday in Freedom from Religion Foundation, Inc. v. Lew, No....more

On-Premises Fringe Benefits, Part I: Is There Such a Thing as a Free Lunch?

It is no secret that many Silicon Valley employers serve free gourmet meals to their employees—the Wall Street Journal, Bon Appétit magazine, Time, Forbes, and other media sources have reported on this benefit. In addition,...more

ACO Participation By Tax-Exempt Healthcare Organizations – Is Tax-Exempt Financing at Stake?

Does A Tax-Exempt Healthcare Organization’s Participation in an Accountable Care Organization (ACO) Adversely Affect Its Tax-Exempt Financing? IRS Notice 2014-67 Provides Guidance....more

IRS Provides Increased Flexibility on Management Contracts for Tax-Exempt Bond-Financed Property

On October 24, 2014, the Internal Revenue Service issued Notice 2014-67 (the “Notice”), which provides important guidance and increased flexibility for issuers and conduit borrowers of tax-exempt bonds regarding contracting...more

Tax Law Blog: More 2015 Tax Numbers Released, Including Tax Brackets

I previously posted about the increase in retirement plan contribution limits for 2015. This week the IRS announced the tax brackets, personal exemption, and standard deduction amounts for tax year 2015. To be clear, the new...more

Should You Transfer Unused Gift and Estate Tax Exemptions to a Surviving Spouse? (Part I)

The word "portability" in an estate tax context refers to the ability to transfer a deceased spouse's unused gift and estate tax "exemption" (technically known as the "basic exclusion amount" or the "BEA") to the surviving...more

Internal Revenue Service Releases Notice Liberalizing the Private Business Use

On October 24, 2014, the Internal Revenue Service (“IRS”) released Notice 2014-67 (the “Notice”), providing guidance with respect to Accountable Care Organizations and their use of tax-exempt bond financed projects. The...more

IRS Releases Favorable Private Business Use Rules for Facilities Financed With Tax-Exempt Bonds

On October 24, 2014, the IRS released Notice 2014-67, which establishes more favorable safe harbors for types of service contracts and other arrangements using property financed with tax-exempt bonds. The Notice also provides...more

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