Tax Liability

News & Analysis as of

Lessons Learned in Conservation Partnerships

The Internal Revenue Code has provided an incentive under Section 170(h) for charitable conservation gifts. Since at least 2002 there has been an interest in combining through partnership those land owners who may have little...more

California Employment Law Notes - July 2015

Employee's Inability To Work For A Particular Supervisor Does Not Constitute A "Disability" - Higgins-Williams v. Sutter Med. Found., 237 Cal. App. 4th 78 (2015) - Michaelin Higgins-Williams worked as a clinical...more

New York Case Highlights Sales Tax Pitfalls for Boarding Operations

Commercial horse boarders and breeders enjoy a fairly broad set of sales and use tax exemptions in New York State. Exemptions covering most of the operation’s purchases are designed to parallel the tax breaks given to farming...more

How Far Back Can a Back Tax Go? Petition for Certiorari in Hambleton Asks Supreme Court to Right Unjust Retroactivity

Retroactivity is an endemic problem in the state tax world. In this year alone, we have seen retroactive repeal of the Multistate Tax Compact (MTC) in Michigan, as well as significant retroactivity issues in New York, New...more

MoFo New York Tax Insights - Volume 6, Issue 7 - July 2015

In This Issue: - Important Changes at NYS and NYC Tax Agencies - Court of Appeals Upholds Constitutionality of Taxing Nonresidents on Gain from S Corporation Stock Sale in Two Separate Decisions - NYC Tribunal...more

Telemedicine Providers: Are My Doctors Employees or Independent Contractors?

Many telehealth companies, particularly those with multi-state footprints, look to an independent contractor model when developing their network of physician providers. An independent contractor model (using 1099 contractors)...more

Pennsylvania’s NOL Cap Litigation Moving Forward

In a Corporate Net Income Tax (“CNI”) appeal filed by Nextel Communications of the Mid-Atlantic, Inc. (“Nextel”), the Commonwealth Court will consider whether Pennsylvania’s statutory cap on net operating loss (“NOL”)...more

Addressing Tax Liabilities In A Business Sale An Important Task

When a business owner is working on selling his or her business, there is a lot of planning that goes into the process. One important aspect of selling a business is to work out a tax strategy. In any business sale, potential...more

Davidson v. Henkel — What’s Going On With Nonqualified Deferred Compensation Plans and FICA

In This Presentation: - Davidson v. Henkel Corp. - The Parties - NQ Plan - The Plan’s Tax Clauses - Davidson’s Pre-Retirement Counseling - 2011 Compliance Review and Letter - Henkel’s Tax...more

Australia: Tax Changes on the Horizon for Expatriates Working in Australia

In May 2015, the Abbott Government announced that, as part of its objectives for the Australian federal budget, it will reform the tax residency rules by creating tougher rules and higher income tax bills for the approximate...more

Tax Due Diligence and Self-Checks of Tax Liabilities

A buyer who orders a tax due diligence review before acquiring a company wants to get information not only about the tax risks that may exist for that company, but also about its existing tax assets (both those assets that...more

One Dollar of Tax Would Have Avoided $94,671.53 of Penalty

A corporation filed a 2008 income tax return reflecting a tax liability of “$0.00.” In the following year, the Corporation made no estimated income tax payments, based on Internal Revenue Code Section 6655(d)(1)(B) which...more

Distressed Download - March 2015

What Happens in Delaware Does Not Always Stay in Delaware: Caesars Victorious in Venue Battle - On Wednesday, January 28, the Bankruptcy Court for the District of Delaware transferred venue for the involuntary bankruptcy...more

Obama Budget Proposal Would Provide Relief for Certain Accidental Dual Citizens

A provision contained in the Treasury’s green book explaining President Obama’s 2016 budget proposals may provide U.S. tax and reporting relief for certain dual citizens. An individual can become a U.S. citizen at birth...more

Be Careful for What You Wish For! - Reconsidering the Tax Traps of the EB-5 Visa

EB-5 Visas have been widely promoted as a legal basis for foreign business owners to gain conditional residency followed by permanent residency in the United States. Nothing hard to understand about that. The combination of...more

"Senate Finance Committee Takes Unanimous Step Toward FIRPTA Reform"

On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more

Appeal Court Confirms Tax Advisors Do Not Owe Common Law Duty to Indemnify

In Addison & Leyen Ltd v Fraser Milner Casgrain LLP, 2014 ABCA 230, the Alberta Court of Appeal confirmed that tax advisors do not owe a common law duty of contribution and indemnity to recipients of their tax advice when...more

Rescission: Another Remedy to Address Unintended Tax Consequences

While the equitable remedy of rectification is often sought as a means to address unintended tax consequences, rescission is also an available remedy in the appropriate cases. The British Columbia Supreme Court’s decision in...more

Possible Tax Consequences of Debt Settlement

People want to pay their debts. If there is one thing I have learned over the last 11 years of practicing law is that people generally want to pay the debts that they have incurred. People usually hire me when they simply...more

Nevada Supreme Court Finds Class of Strippers Were Employees

Given the extensive use of euphemisms in the exotic dancing trade, we’ll apologize in advance for any unintended puns. We’ve written on the issue of the classification of exotic dancers or strippers in the past [April...more

McKesson: Taxpayer Seeks to Raise Additional Issue on Appeal

The transfer pricing case of McKesson v. The Queen has raised procedural issues that are without precedent in Canadian tax cases. This week, those procedural issues became a central part of the matters that will be considered...more

Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders  [Video]

Nov. 3, 2014 -- Allen Appel, Professor at New York Law School and Director of the International Tax Program, talks with Lee Pacchia about corporate inversions....more

New Jersey Division of Taxation’s 2014 Tax Resolution Initiative – Not To Be Confused With An Amnesty

The New Jersey Division of Taxation (Division) is trying to help taxpayers resolve unpaid tax liabilities for tax periods 2005 through 2013. Through November 17, 2014, the Division is offering taxpayers that pay all tax and...more

Maddin: Failure to Inquire Leaves Director Liable

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

Guindon: SCC Hearing Scheduled for December 5, 2014

The highly-anticipated appeal to the Supreme Court of Canada in Guindon v The Queen has been scheduled for hearing on December 5, 2014, and the parties have now filed their factums in the appeal. The appeal concerns...more

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