Tax Planning

News & Analysis as of

Recent Tax Developments

The following is a summary of the most important tax developments that have occurred in the past several months that may affect you, your family, your investments, and your livelihood. Please call us for more information...more

The Inversion Craze: Will Today's Routine Tax Planning Be Retroactively Outlawed?

Alongside the more typical summer fare, such as coverage of the best beach reading and the latest action movie blockbuster, this summer the media have been abuzz with seemingly daily reports on the latest so-called...more

Transitioning the Family Business to the Next Generation

The transition of a family owned business involves a variety of legal and tax issues. While most business owners plan to avoid taxes and develop creditor protection strategies, business owners also should be focused on...more

Goodwill Owned by a Shareholder Can Provide Tax Planning Opportunities

A recent U.S. Tax Court case reminds us that the personal goodwill owned by the principal shareholder/employee can provide significant tax planning opportunities. Generally, the sale of assets by a "regular" corporation...more

For Love or Charity – A Charitable Bailout Using Charitable Remainder Trusts for the Sale of a C Corporation

I have personally observed in my professional travels that many taxpayers are reluctant charitable donors. However, we you remind a business owner that they only have three choices when it comes to taxes (1) Pay yourself;...more

5 Questions to Ask Before Making Gifts for Medicaid or Tax Planning

Many seniors consider transferring assets for estate and long-term care planning purposes, or just to help out children and grandchildren. Gifts and transfers to a trust often make a lot of sense. They can save money in taxes...more

Swimming in the Deep End – The Surprising Utility of Pooled Income Funds for High Net Worth Tax Planning

Overview - The old cliché about Charity is that “Charity begins at home.” The federal government has always recognized the social benefit of providing tax incentives for individual and corporate taxpayers in order to...more

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

Affirmative Use of U.S. Partnerships in Inbound Tax Planning

A “U.S. shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed. In general, a CFC...more

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

An Appreciation for Hedging Your Bets on Deferred Compensation: IRS Issues Revenue Ruling 2014-18 Under Section 457A of the...

Under Section 457A of the Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those entities....more

CRA Update: Aggressive Tax Planning

At the Toronto Centre Canada Revenue Agency & Tax Professionals Breakfast Seminar on June 10, 2014, the Canada Revenue Agency (“CRA”) provided an update on selected CRA Compliance Measures in the Aggressive Tax Planning...more

Developing Your Government Investigations Playbook: What Your Nonprofit Should Be Doing Now to Prepare for the Future

In this presentation: - Risk Management - Document Management - Response Team - Response Drills - Cultivate Allies - Excerpt from Document Management: Counsel: -...more

UK's Upper Tribunal decision in Greene King: tax and accounting

SPEED READ - The Upper Tribunal has upheld the Firsttier Tribunal’s (FTT’s) decision in Greene King. Planning designed to obtain a deduction with no taxable receipt was held to have failed. While the law has changed...more

Tax Planning for the Privatization of the Space Industry

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more

Tax And Business Planning For Farmers To Avoid Higher Taxes And Loss Of Subsidies

The Agricultural Act of 2014 (aka - the 2014 Farm Bill) has been controversial, to say the least. Among its many changes are an $8 billion cut to the “food stamp” program. The Farm Bill also drastically modifies or ends...more

Proposed Regulations Provide Greater Certainty on the REIT Classification of Solar and Other Non-Traditional Assets

The Internal Revenue Service (the “IRS”) and Treasury Department have proposed regulations (the “Proposed Regulations”) under Section 856 of the Internal Revenue Code providing guidance for analyzing whether non-traditional...more

S Corporations - Time To Drop Them!

Most of us know that S corporations are reasonably tax efficient from an operating standpoint: leaving aside Illinois replacement tax, only one level of tax is paid on company earnings (at the shareholder level). We also know...more

From Nuyorican to Puerto Rican - A Reverse Economic Pilgrimage to the Land of Los Padres!

The New York metropolitan area has always been the largest Puerto Rican community outside of Puerto Rico. Puerto Ricans have been coming to “Nueva York” since Puerto Rico was a Spanish colony. The heaviest migration of Puerto...more

Minnesota Income Tax Residency Law— Recent Developments and Planning Considerations

On April 16, 2014, the Minneapolis Star Tribune published an article by Adam Belz titled, “Minnesota’s wealthy caught in a tight tax net over residency.” The article discussed the Minnesota Department of Revenue’s approach to...more

Fasten your seat belts: European Commission to use state aid powers to scrutinize aggressive tax planning

An important message to all tax planners: The European Commission’s Directorate General for Competition has declared war on "fiscal optimization." It intends to use the antitrust stick to overcome the lack of tax...more

International Tax News - February 2014

IRS RELEASES ITS “ROADMAP” OF THE TRANSFER PRICING AUDIT PROCESS - The US Internal Revenue Service has released its Transfer Pricing Audit Roadmap, a 26-page outline of the two-year transfer pricing audit process,...more

5 Estate Planning Mistakes You Should Try to Avoid

In your experience, what’s the most costly mistake people make when preparing estate plans, and what can they do to fix them? That’s the question we recently put to attorneys writing on JD Supra....more

Q&A With Baker Botts' Richard Husseini

Richard Husseini is the chairman of Baker Botts' tax department where he maintains a unique tax practice combining federal tax controversy and litigation with sophisticated federal tax planning. Husseini represents...more

Consider Tax Implications in Settlement Agreements

When considering settlements, it is also important to consider one of life’s certainties: taxes. A potentially taxable event may occur whenever money changes hands—even in the context of a settlement. See Internal Revenue...more

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