Tax Liability

News & Analysis as of

Governor Christie’s Veto of Hospital Fee Bill Tees Up Additional Litigation

On January 19, 2016, New Jersey Governor Chris Christie vetoed bipartisan legislation that sought to establish hospital “community service contributions” (“CSCs”) in hopes of avoiding litigation concerning the tax burden of...more

New IRS Audit Rules: Partnerships and LLCs Should Name A Partnership Representative For IRS Audits

New legislation will govern IRS audits of partnerships and LLCs for tax years beginning after December 31, 2017. The new rules will affect both existing LLCs and partnerships as well as new partnership and LLC agreements,...more

New FIRPTA Reform Creates PATH to Potential Benefits for Existing REITs and Foreign Investors in the United States

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Among other changes, the PATH Act significantly modifies provisions of the Internal Revenue Code of...more

Recent Changes to the Tax Matters Partner Designation May Prove Costly to the Unwary

One choice all joint venture devotees face in negotiating each new venture is who to designate as the tax matters partner. Recent changes to the law make this decision much more important and may prove costly to those who are...more

Budget Act of 2015 Alert

New Partnership Audit Rules Will Impact New and Existing Partnership Agreements - The Bipartisan Budget Act of 2015 will change significantly the audit, assessment, and collection procedures applicable to entities...more

New Rule Requires Federal Contractors to Disclose Federal Tax Delinquencies and Felonies

On December 4, 2015, the Department of Defense, General Services Administration and the National Aeronautics and Space Administration issued an interim rule amending the Federal Acquisition Regulations to implement sections...more

Recent development on taxation of securities lending transactions

On 13 January 2016 the German Federal Finance Court (Bundesfinanzhof –“BFH”) published its ruling on securities lending transactions (“Ruling”). The Ruling was long-awaited and rumor had it that it might bring about a...more

Reed Smith Clients Vindicated – Illinois Circuit Court Grants Motion to Dismiss in Qui Tam Winery Cases

On January 20, 2016, Judge Thomas Mulroy of the Cook County Circuit Court in Chicago granted the Illinois Attorney General’s Motions to Dismiss numerous qui tam cases brought against California wineries, 17 of which are...more

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

Where Do You Think You’re Going?

Congress recently passed H.R.22. It was signed by the President on December 4th and it became Public Law No: 114-94. The law is known as the “Fixing America’s Surface Transportation Act” (“FAST”)....more

100% QSBS Exclusion Soon to be Made Permanent

The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more

100% Exclusion for Gains from Qualified Small Business Stock Soon to be Made Permanent

The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more

Creating a Social Network of Tax Savings: The Use of LLCs in Structuring Philanthropic and Public Good Activities

The use of a limited liability company (LLC) by Mark Zuckerberg and his wife Priscilla Chan as the vehicle for advancing of “philanthropic, public advocacy, and other activities for the public good” has recently received a...more

LLCs: A New Horizon for Charitable Giving?

When Mark Zuckerberg recently announced that he was giving away up to 99 percent of his Facebook shares (valued at approximately $45 billion), he was severely criticized for it. Zuckerberg and his wife created the Chan...more

Pennsylvania’s Commonwealth Court Decides in Favor of Reed Smith Client - Corporate Tax Refund Claim Filed Within Three Years of...

In a unanimous decision, the Pennsylvania Commonwealth Court held that the three-year time limitation for filing refund claims for corporate taxes begins on the date a corporation’s tax return is filed, not the original...more

New IRS Early Interaction Initiative Will Help Employers Stay Current with Their Payroll Taxes

To help employers stay current with their employment tax responsibilities, the IRS announced on Dec. 8, 2015, a new early initiative to notify employers who may be falling behind on payment of their employment taxes. IRS News...more

New Act Significantly Alters Partnership Audit Procedures

The recently enacted Bipartisan Budget Act of 2015 repeals the current Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and Electing Large Partnership (ELP) partnership audit regimes and replaces them with a new...more

Year-End Tax Planning 2015

As the end of the year approaches, it is a good time to think of planning moves that will help lower your tax bill for this year and possibly the next. Factors that compound the challenge include turbulence in the stock...more

Congress Passes Law Revoking Passports of Those with “Seriously Delinquent Tax Debt”

On December 3, 2015, Congress passed a bill requiring the IRS to notify the State Department of any taxpayer with “seriously delinquent tax debt” and requiring the State Department to revoke that taxpayer’s passport until the...more

New Law Authorizes State Department to Revoke U.S. Passports of Tax Delinquents

This afternoon, President Obama signed into law a five-year, $305 billion highway funding bill that includes several controversial tax measures designed to help fund the legislation. One provision in the legislation...more

Year-End Gift Opportunities

As 2015 comes to a close, we remind you to consider making gifts to minimize your potential tax liability and to maximize your use of available exemptions in order to reduce your ultimate estate tax liability. As you may...more

IRS Audits of Partnerships: Big Changes are Coming

The Bipartisan Budget Act of 2015 (the “Act”), which was signed into law on November 2, will drastically change the way entities (including limited liability companies) treated as partnerships for U.S. federal income tax...more

Partnership-Level Tax Under New Audit Rules

The Bipartisan Budget Act of 2015, signed into law on November 2, 2015, has significantly changed the partnership tax audit rules, effective for tax years beginning after December 31, 2017. Under the current partnership...more

New Hampshire Lowers Tax Rates, Creates Amnesty and Voluntary Disclosure Programs

After lengthy negotiations between legislators and Governor Maggie Hassan, New Hampshire enacted significant tax changes, including a cut to business tax rates, an increase in the research and development tax credit, and the...more

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

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