The 2010 Tax Relief Act and your estate plan
A Better 2012 for BigLaw (With Big Asterisks)
The Maine Legislature ended its tumultuous session on July 16, 2015. After an advisory opinion by the Maine Supreme Court, we now know which bills actually became law. As usual, a number of significant tax issues were...more
According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more
On June 29 and 30, 2015, the Connecticut General Assembly conducted a special legislative session following the close of the 2015 regular session. Among other things, the General Assembly passed a bill to implement the state...more
Recently introduced bills are indicative of the fact that the estate, gift and generation skipping transfer taxes are still a topic of considerable political debate.
Recently, the Responsible Estate Tax Act was...more
Generally, the first criterion for determining whether an individual is subject to probate or to estate or inheritance tax in a state is the individual’s domicile at the time of his or her death.
In an increasingly...more
Because of the increases to the income tax rates and the reduction in the estate tax rates in recent years, anyone holding appreciated assets in a grantor trust should consider exchanging high-basis assets that have less...more
Upcoming IRS regulations may significantly limit and reduce planning opportunities to transfer minority interests in closely held entities to family members and increase the transfer tax cost associated with moving such...more
The Conservative Government has settled in and turned its attention to the world of employment law. We update you below on five of its key moves.
1. Gender Pay Gap Reporting - The Government will enact legislation...more
In two recent cases, taxpayers have successfully challenged state taxation of trust income on the basis that the taxing states had a minimal connection to the trust. In The Kimberly Rice Kaestner 1992 Family Trust v. North...more
On July 29, 2015, two members of the U.S. House of Representatives introduced draft legislation for public comment that would provide U.S. companies with a significant tax break on profits derived from qualifying intellectual...more
Several press articles in recent weeks have anticipated the upcoming enactment of the Ministerial Decree which will eventually implement the Italian Patent Box regime. The Ministry of Economics and Finance announced on 29...more
Following up on my post from last week, presidential candidate Hillary Clinton has now provided more specific information on her proposed capital gains rates hike.
For high income filers (couples making at least $465,000...more
Piggy-backing on my colleague Drew’s sales tax update last week on new use tax rules for yachts already in effect, I’m writing with another timely update on New York’s soon-to-be-effective sales and use exemption rules for...more
On July 23, 2015, the Internal Revenue Service ("IRS") issued long-awaited proposed regulations discussing the taxation of management fee arrangements commonly used by private equity funds and their management. The proposed...more
The Obama administration and top lawmakers are in discussions regarding a potential overhaul of how the United States taxes U.S. multinational corporations. Topics under consideration include eliminating the U.S. approach of...more
The CRA recently provided its views on whether digital currency, including Bitcoins, are considered “specified foreign property” under the foreign property reporting rules in section 233.3 of the Income Tax Act.
Business succession planning in the current tax environment may require an adjustment in thinking from traditional planning. Traditional planning usually attempts to transfer ownership of the business to the next owner (often...more
Hillary Clinton is expected to propose later this week a revamping of capital gains rates. While the specifics are not yet released, Clinton’s proposal is expected to increase the current maximum capital gains rate for...more
Fourth of July has come and gone. This year, nonresidents (more on this later) who brought a new boat to New York for the first time were hit with a breath of fresh air—and I’m not talking about the fresh air from [insert any...more
Governor Dannel Malloy recently signed a budget package, retroactive to January 1st of this year, which increases the income tax rate for the state's highest earners and makes some notable changes to estate taxes and probate...more
It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more
On 6 November 2013, the Federal Government announced that it would introduce a 10% non-final withholding tax on the disposal of certain taxable Australian property by foreign residents. This measure aims to assist the...more
Federal income tax is a tax on “net” income – gross income less allowable deductions. Unless, however, you are a drug dealer – Code Section 280E does not allow sellers of federally controlled substances to deduct their...more
The recent U.S. Supreme Court decision in Obergefell v. Hodges, 135 S.Ct. 1039 (June 26, 2015),answered definitively the lingering questions following the Court’s decision last year in Windsor about whether states could...more
While not purporting to give specific advice on Nevada tax law, the following is a summary of some of the general principals underlying the new tax law. A new Nevada Commerce Tax (“NCT”) was signed into law by Nevada Governor...more
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