Corporate Taxes

News & Analysis as of

UK Autumn Statement 2014

Today’s Autumn Statement saw financial institutions hit by a surprise proposal to limit the proportion of their profits which can be reduced by the carry forward of past losses, which will mean tax is paid on those profits...more

Autumn Statement 2014: Key Implications for U.K.-Based Alternative Asset Managers and Their Funds

Shortly after 12.30 p.m. today, the U.K. Chancellor of the Exchequer, George Osborne, delivered the last Autumn Statement before next year’s general election....more

Application and Sale of Restricted Tax Credits

The Pennsylvania Department of Revenue has issued detailed rules for the application and sale of various Pennsylvania tax credits. Corporation Tax Bulletin 2014-04 replaces Corporation Tax Bulletin 2011-03. The Bulletin...more

UK Chancellor of the Exchequer Issues Annual Autumn Statement

UK Chancellor of the Exchequer George Osborne delivered his annual Autumn Statement on 3 December 2014. This Alert highlights the key contents of the statement, but the detail of the proposals will become apparent only on the...more

2014 May Be the Last Year for Valuable "Tax Extenders"

Last week, President Obama threatened to veto an agreement between Senate Democrats and House Republicans on a collection of tax breaks known as “tax extenders.” The deal would have been a huge win for manufacturing, because...more

Focus on Pennsylvania Corporate Taxes

With the November 4th election of Democrat Tom Wolf as Pennsylvania’s next Governor, Pennsylvania corporate taxpayers face an interesting budget season in 2015. During the campaign, Wolf advocated for a severance or...more

Year-end Uncertainty Highlights Need for Tax Reform

As we approach year-end, we again find ourselves in an all-too-familiar and unsettling situation — one in which we do not know the rules of the game we are about to play. Many popular tax planning opportunities, like the R&D...more

Tennessee Tax Department Releases Letter Rulings

The Tennessee Department of Revenue recently released several Letter Rulings analyzing various Tennessee tax issues, including the application of sales and use taxes to cloud collaboration services and software consulting...more

Beleaguered D.C. Taxpayers Achieve Another Success in Ongoing Challenges to the Methodology Used in the District’s Transfer...

On Friday, November 14, 2014, an administrative law judge (ALJ) issued three identical orders granting the taxpayer’s motion for summary judgment in Hess v. OTR, Shell v. OTR and ExxonMobil v. OTR. In these orders, the ALJ...more

Spanish tax reform: Corporate Income Tax

The new legislation will be applicable for fiscal years starting as from 1 January 2015, although some new measures will only be effective as from 2016. The main objectives of this tax reform are: on one hand,...more

Monitoring Swiss tax developments - Part II: a positive view on the Swiss tax regime

As part of DLA Piper’s ongoing monitoring of the evolving Swiss tax landscape, this article updates key, high-level takeaways based on recent meetings surveying ongoing developments, after the Swiss government’s September...more

California FTB to Consider Revisions to Combination Regulations for Mixed Financial and Non-Financial Reporting Groups

The California Franchise Tax Board (FTB) has announced the scheduling of an Interested Parties Meeting (IPM) for December 4, 2014 on the topic of possible regulatory efforts regarding the proper treatment of mixed...more

Legal Alert: Has New York City Added a Fourth Element for Determining a Combined Group?

A New York Tax Appeals Tribunal Administrative Law Judge (ALJ) recently determined that a federal savings and loan association was not required to include a subsidiary, which was formed as a Connecticut passive investment...more

Popular Corporate Tax Reads on JD Supra

Reading recap: a look at some of the most popular Corporate Tax articles on JD Supra right now....more

Focus on Tax Strategies & Developments - November 2014

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

MoFo New York Tax Insights - Volume 5, Issue 11 - November 2014

In This Issue: - Court Orders Department of Finance to Release Corporate Tax Return Records to City Comptroller - ALJ Upholds State Tax Department Policy on Personal Liability of LLC Members for Sales...more

Take Two: Massachusetts Department of Revenue Releases Revised Market-Based Sourcing Regulation

Late last week, the Massachusetts Department of Revenue (the Department) released a revised draft regulation on Massachusetts’s new market-based sourcing law. The changes made by the Department to purportedly address...more

Back in the game: The rise of US M&A

US M&A is bouncing back - After a tough few years, acquisitions in the United States have seen a remarkable resurgence - The first half of 2014 saw a great dealmaking revival in the United States. Deal values...more

25 Ways Manufacturers Can Drive Profitability

Cohen & Company recently hosted “25 Way to Drive Profitability,” a workshop in Youngstown geared specifically toward manufacturers. Beginning with an overview by Rick Schiraldi of the Valley’s manufacturing roots and history,...more

Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders  [Video]

Nov. 3, 2014 -- Allen Appel, Professor at New York Law School and Director of the International Tax Program, talks with Lee Pacchia about corporate inversions....more

New Jersey Tax Court Finds Two Pennsylvania Taxes Are Not Required To Be Added Back

In a Corporation Business Tax (CBT) case, PPL Electric Utilities Corporation v. Director, Division of Taxation, Dkt. No. 000005-2011 (N.J. Tax. Ct. Oct. 2, 2014), the Tax Court of New Jersey found for the taxpayer and held...more

IRS Proposes To Eliminate ‘Confusing’ 36-Month Non-Payment Testing Period for Cancellation of Debt

The Internal Revenue Service recently proposed very well-received regulations under Section 6050P of the Internal Revenue Code (the Code) that would eliminate the requirement for financial entities to treat debt as canceled...more

The Prospects for Corporate Tax Reform

As the 2014 midterm elections approach, speculation is widespread as to whether tax reform can be successfully pursued in 2015. The successful 1986 Tax Reform Act navigated through a politically divided Congress a full...more

Indiana Department Of Revenue Adds Back Manufacturer’s Substantial Inter-Company Interest Expenses Claimed On Corporate Income Tax...

In a September 2014 ruling, a multi-national manufacturer with Indiana locations protested the Indiana Department of Revenue’s decision to add back interest expenses claimed on its corporate income tax returns. Manufacturer...more

Southeast State & Local Tax: Important Developments - September/October 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA - INDIVIDUAL INCOME TAX...more

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