Tax Planning

News & Analysis as of

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

The Supreme Court of Canada Settles the Issue: Quebec Taxpayers May Seek Rectification for Mistakes that Have Unintended Tax...

On November 28, 2013, the Supreme Court of Canada rendered an important decision recognizing the right of the parties, under Quebec civil law, to rectify an agreement that gave rise to unintended tax consequences, with...more

Q&A With Morrison & Foerster's Mitch Newmark

Mitchell A. Newmark is a partner at Morrison & Foerster LLP and is concentrated on state and local tax litigation and appeals before administrative and judicial bodies around the country. Newmark also advises companies and...more

Auto-Enrolment: How To … … Operate Salary Sacrifice Alongside Automatic Enrolment

INTRODUCTION - It is now just over a year since the first employers reached their automatic enrolment staging dates and therefore many of the practical issues that arise for employers when implementing the reforms are...more

Q&A: Is There Much I Can Do with My IRA in Terms of Tax Planning?

My largest asset is an IRA. I hear there is not much I can do with an IRA in terms of estate tax planning. Is that true?...more

The Aftermath of a Section 355 Transaction (Part 1)

Section 355 is one of the few bright spots remaining for corporate tax planners since repeal of the General Utilities doctrine in the mid-1980s. However, the tax-free treatment of corporate spin-offs and other separations...more

Tax planning for year-end; expiration of the 100% tax exemption for gain on QSBS

Just a reminder that the temporary 100% exclusion for Federal capital gains tax on the sale of “qualified small business stock” (“QSBS”), under Section 1202 of the IRS regulations, is set to expire at the end of calendar year...more

The 336(e) Election: Possible Deemed Asset Sale Treatment When a 338(h)(10) Election is Unavailable

For U.S. federal income tax purposes, a purchaser in a corporate acquisition typically prefers to acquire assets of a target corporation (“Target”) rather than stock because a purchaser that acquires assets is able to “step...more

The New 3.8-Percent Tax Applies To Trusts And Estates

As we noted in a prior Estate Planning Update, 2013 brought with it a new 3.8-percent Medicare Contribution Tax on net investment income (interest, dividends, annuities, royalties, rents, capital gains, and passive activity...more

Tax Planning in Grey Divorce

Grey divorce involves individuals over the age of 50 who are ending a marriage. Because many people over the age of 50 thought they would be retiring sooner rather than later, divorce often means new financial plans are...more

Tax Planning For U.S. Companies With Latin American Operations

Pass-through structures - Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries....more

Placing Your Aircraft with an Aircraft Charter-Management Company

The management, operation and maintenance of a business aircraft is a complex and expensive undertaking. Although some aircraft owners may be able to hire experienced pilots and mechanics, a good charter-manager brings...more

Breaking Bad And Tax Planning?

In last Sunday’s final episode of “Breaking Bad”, Walter White broke into his former business partner’s house (Elliot and wife Gretchen). Reason? To give them close to a million dollars in cash so they would set up a...more

A Review of the Qualified Personal Residence Trust (QPRT) in Estate Planning

At the end of the 20th century, real estate values were growing at phenomenal rates with no end in sight. By the end of 1999, the S&P 500 featured an astounding five-year average annual return of 28.56%. For the 2000...more

Challenges To Deducting Settlement Payments Under The False Claims Act: Fresenius Sheds Light On The Burden

Whether a business may deduct litigation settlement payments can have a substantial real dollar impact on the business. In the midst of combating potential litigation, companies rarely first focus on the potential tax impact...more

Junior Goes to College! Innovative Strategies to Save for Your Children's College Education with Pre-Tax Dollars

Overview - The cost of college tuition has gone through the roof. The average cost of a private university can range from $40,000-60,000 per year. The cost of a public university is a lot less in most cases except that...more

Same Sex Couples Should Check On Their Wage Withholding And Estimated Tax Payments Now

A downside to the IRS’ recognition of same sex marriages is that such couples must file in 2013 as married – they can file jointly or or as married filing separately. This means they may now suffer higher income taxes due to...more

Using a Charitable Trust to Offset Capital Gains

We are approaching the extended income tax deadline for 2012 and it reminded me (as if anyone could forget) that 2013 carries significantly higher income tax rates for a lot of folks. We have the Medicare surcharge, and most...more

Global Tax Report - September 2013: Intellectual Property Tax Planning

In This Issue: - United States: Benefits of Intangible Property Migrations - United Kingdom: Innovation: The Name of the Game - Germany: OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) Within the...more

Tax Law Blog: IRS Statement on DOMA and Tax Tips for Newlyweds

On June 26, the United States Supreme Court ruled a portion of the Defense of Marriage Act (DOMA) was unconstitutional. A full explanation of the article is available on a prior post. Experts in the tax realm have mixed views...more

New 2013 Estate Tax Laws Warrant Exclusion And Portability In Planning

The new estate laws are challenging to comply with and will require most high net worth individuals to review their existing plan. One of the major issues is how the trust is divided on the death of the first spouse, and who...more

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