Corporate Taxes

News & Analysis as of

Patent box concept emerges on the tax reform agenda for US Congress

Key tax writers in Congress are indicating that once Congress disposes of pending trade legislation, they will turn to their top legislative priority: reaching a consensus on international and business reform by the end of...more

Tax Law

In This Chapter: Tax Law: Annual Survey of Wisconsin Law - - Case Law - Statutory Developments - Administrative Developments - Excerpt from Case Law: Individual and Fiduciary Income Tax...more

Australian Tax Alert – Victoria Introduces 3% Stamp Duty Surcharge For Foreign Purchasers Of Residential Property

As announced in the Victorian 2015-16 budget, a bill introducing an additional 3% stamp duty surcharge on "residential property" purchases by "foreign purchasers" was introduced into the Victorian parliament on 5 may 2015....more

Tax Policy Update

NUMBER OF THE WEEK: 61. The number of countries that have signed on to implement the OECD’s multilateral agreement for the automatic exchange of tax information, in conjunction with the ongoing Base Erosion and Profit...more

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

Licensed Insurance Companies Exempt from Maryland Income Tax

Are insurers licensed to do business in Maryland subject to state income tax on profits derived from sources other than insurance policy premiums? That was the question before the Maryland Tax Court in National Indemnity...more

Kruger: FX Derivatives Gains/Losses Taxed Only When Realized

In Kruger Incorporated v. The Queen (2015 TCC 119), the Tax Court held that the taxpayer could not value its foreign exchange options contracts on a mark-to-market basis, with the result that certain losses were not...more

Charging Orders on LLCs in Kentucky

The organization of any business as a limited liability company ("LLC") brings with it attendant protections for the members from the liabilities that arise in the course of the business as well as beneficial tax treatment....more

BP Canada: CRA Entitled to Tax Accrual Working Papers

In BP Canada Energy Company v. Minister of National Revenue (2015 FC 714), the Minister brought an application pursuant to subsection 231.7(1) of the Income Tax Act (Canada) (the “Act”) before the Federal Court of...more

Taking Your Business International

Going international is a complicated undertaking. The steps required will depend on your specific situation and concerns. The following outlines, in very general terms, some of the issues you must consider as you begin to...more

Proposed New UK Tax Rules for Debt Restructuring

1. Executive Summary - The U.K. corporate tax landscape has been undergoing reform for a number of years. A significant part of the changes involves the ongoing modernization of the U.K.’s complex tax regime for...more

First Marblehead Requests U.S. Supreme Court Review In SINAA Sourcing Appeal

In a case of interest for any taxpayer with substantial securitization activities, First Marblehead Corporation and Gate Holdings, Inc. have requested United State Supreme Court review of a recent determination of the...more

U.S. Supreme Court Holds Maryland Personal Income Tax Unconstitutional Under Commerce Clause

In Comptroller of the Treasury of Maryland v. Wynne, Dkt. No. 13-485 (U.S. May 18, 2015), the U.S. Supreme Court found that Maryland’s system of personal income taxation violated the nondiscrimination prong of the dormant...more

Wynne Is a Win for Corporate Taxpayers

On May 18, 2015, the U.S. Supreme Court decided Comptroller of the Treasury of Maryland v. Wynne, No. 13-485, holding that the absence of a credit against the local portion of the state’s personal income tax scheme was an...more

Tax Policy Update

NUMBER OF THE WEEK: 68,000. The estimated number of vehicles that traverse the Memorial Bridge between Arlington, Va., and Washington, D.C., each day—now with increasingly frustrated drivers stuck in snarled traffic after two...more

IRS Updates EPCRS Correction Methods and Procedures

Reflecting comments it requested, and others it received, the Internal Revenue Service (IRS) recently issued two updates which modify the Employee Plans Compliance Resolution System (EPCRS), which is the comprehensive system...more

NYS Tax Appeals Tribunal Provides Guidance Respecting Unitary Business Determinations

The New York State Tax Appeals Tribunal has just provided timely guidance respecting the unitary business rule in New York State. In SunGard Capital Corp. and Subsidiaries (DTA Nos. 823631, 823632, 823680, 824167, and...more

Maryland Tax Court Continues Disturbing Trend in Post-Gore Cases with Recent Staples Decision

Last week, the Maryland Tax Court issued its decision in the consolidated cases of Staples, Inc. v. Comptroller of the Treasury and Staples the Office Superstore, Inc. v. Comptroller of the Treasury. The cases involved the...more

Patent box concept emerges on the tax reform agenda for US Congress

Key tax writers in Congress are indicating that once Congress disposes of pending trade legislation, they will turn to their top legislative priority: reaching a consensus on international and business reform by the end of...more

Mac’s: Quebec CA Affirms Denial of Rectification

In Mac’s Convenience Stores Inc. v. Canada (2015 QCCA 837), the Quebec Court of Appeal affirmed a lower court decision (2012 QCCS 2745) denying rectification of corporate resolutions that had declared a dividend that...more

North Carolina Moves Towards Single Sales Factor and Market Sourcing

An earlier Tax Alert discussed the possibility that North Carolina would adopt the single sales factor method of apportioning the business income of multi-state corporations. During the current legislative session, single...more

Should You Be an LLC or S Corp?

The answer is it depends, as a business owner, on what your goals and objectives are. Both LLCs and S corporations are tax efficient. LLCs and S corporations are both pass-through entities; meaning, generally speaking,...more

New Tax Amnesty Opportunity for Indiana Business Taxpayers

On May 7, 2015, Indiana Governor Mike Pence signed into law P.L. 213, which establishes a tax amnesty program that might give business taxpayers with concerns about Indiana tax reporting a great opportunity to settle any...more

Diverted Profits Tax: counterbalancing the UK's "open for business" agenda?

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of...more

Guide To Doing Business in Australia: Taxation (Updated)

TAXATION - 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...more

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