Tax Liability

News & Analysis as of

Do I Owe Income Taxes When I Rent Out My Home?

Over the summer, Brad Bevos’ company relocated him from Austin to Springfield, Illinois. A University of Texas alum and huge Longhorn football fan, the move bummed Brad because he won’t be able to attend home games this...more

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

Global Tax News: Hard times in the oil patch: tax implications for investors in the era of price fluctuations

The current decline in oil prices, which continues to show no signs of a long-term reversal, is having a great many unexpected and unwanted consequences, many of which may turn into long-lasting troubles for the oil and gas...more

Illinois House Revenue Committee Holds Hearing on Vacancy Fraud Act

While overall there is little activity in the General Assembly, the House Revenue Committee is meeting today for a hearing on an interesting piece of property tax legislation. The hearing is on HB4363, which would create the...more

Hillary Clinton Advises of Changes She Would Make to the Estate Tax Rate

And its not downward – surprise! Last week, Hillary advised that she would like to move the highest estate tax rate from its current 40% to 65%. ...more

Mission Near Impossible - Reliance on Professionals Defense to Late Filing and Payment Penalties

An estate sought relief for $1.189 million in penalties for the late filing of a Form 706 and the late payment of estate taxes when the filing and payment were over a year late. The U.S. District Court granted the...more

New FAQs Clarify Shareholder Approval Rules For Stock-For-Tax Withholding

It has been close to a decade since the New York Stock Exchange (NYSE) last updated its set of frequently asked questions (FAQs) regarding equity compensation plans. On August 18, 2016, the NYSE released updated FAQs and,...more

If you are an “Expat”, or thinking about “Expatriating”, think about this!

Thinking about giving up your US citizenship pending the results of the Presidential election in November 2016? Concerned because you have been an “Expat” for a long time and have not filed US Tax returns? Just realized that...more

Details of 2017 Pennsylvania Tax Amnesty Announced

The Pennsylvania Department of Revenue (the Department) has just released details of the tax amnesty authorized by the 2016-2017 Budget passed in July 2016. The tax amnesty is a tremendous opportunity for taxpayers who owe...more

End of NJ-PA Income Tax Compact Would Affect Tax Liability of Thousands of Commuters

Pennsylvania and New Jersey commuters who live in one state and work in the other could face materially increased state tax withholding if a nearly 40-year-old tax reciprocity compact is terminated in January under an...more

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax...more

New Countries Eligible for Italy's White List

In the Official Gazette No. 195 of 22 August 2016, the Italian Government published the Ministerial Decree of 9 August 2016 (the "Decree") that amended the list of countries and territories "allowing an adequate exchange of...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

Canadians Who Invested in U.S. LLPs and LLLPs Need to Rethink Their Choice of Entity

Historically, Canadian investors in U.S. partnerships benefitted from an extremely efficient income tax structure – i.e., a single level of tax, credit against Canadian taxes for taxes paid in the U.S., and an ability to...more

IRS Attempts Collection Against Surviving Spouse and Marital Deduction Property

In a recent U.S. District Court case from the Southern District of California, the court ruled on several motions to dismiss relating to the IRS' attempt to impose liability on a surviving spouse for estate taxes on the...more

Arizona Offers Rare But Limited Opportunity to Avoid Penalties and Interest, and Optional Payment Plan – Application Deadline:...

On the heels of a very successful program that ended less than a year ago, the Arizona legislature has required the Arizona Department of Revenue (ADOR) to establish and administer a second “tax recovery program” that can...more

Do You Know About the 4 Scenarios in the IRS Collection Process?

The IRS collection process begins when IRS does not receive full and timely payments from a taxpayer after it issues a collection notice. Based on the information in the taxpayer’s 1040 tax return, if the taxpayer does not...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

Pennsylvania Tax Developments - A Reed Smith Quarterly Update

Is Pennsylvania bringing back its tax on “computer-related services”? Pennsylvania’s new “Netflix” tax (enacted as part of Act 84 of 2016) covers more than just digital downloads and streaming services. Effective August 1,...more

Keeping Your Team Motivated: A Profits Interest as an Equity-Based Incentive

Say you own one-half of an LLC that is taxed as a partnership. You and your partner invested the initial capital that was necessary to get the business up and running, and you both built the business with the help of a few...more

New Rules on Section 83(b) Elections

Prior to a recent change, in order for a Section 83(b) election to be effective, the taxpayer had to: - File the Section 83(b) election within 30 days of the receipt of restricted property (typically, restricted stock)...more

Executrix Held Liable Under Federal Claims Statute For Actions Taken Prior to Appointment as Executrix

A decedent died while owing over $340,000 in unpaid federal income tax liabilities. His estate was insolvent. The assets of his estate consisted almost entirely of a 100% interest in one corporation and 50% of another...more

Pennsylvania Tax Amnesty Enacted

A new Pennsylvania tax amnesty program is coming. It was enacted as part of the state’s 2016–2017 budget process. Taxpayers with unfiled state tax returns or returns that need to be amended will be able to pay the tax and...more

IRS Wins Debt vs. Equity Case

A frequent area of dispute between taxpayers and the IRS is whether an indebtedness obligation should be treated as debt, or an equity investment, for income tax purposes. Taxpayers often seek debt treatment to obtain...more

DC Circuit Ruling Threatens to Topple FERC Tax Allowance Policy

Court rules that FERC policy permitting a tax allowance for pass-through entities may unjustifiably permit “double-recovery” of tax expense. On July 1, the US Court of Appeals for the District of Columbia Circuit issued...more

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