Corporate Taxes

News & Analysis as of

Recent U.S. Tax Developments Affecting Publicly Traded Partnerships

Partnerships targeted to widespread investors are a popular investment vehicle and a significant source of funding for oil and gas projects. However, their use is affected by the publicly traded partnership (“PTP”) tax rules....more

Recent Developments - Australian Transfer Pricing (TP) Rules: Time To Step Up

With the Australian Taxation Office's (ATO) escalating focus on international profit shifting, it is essential for multinational taxpayers (MNEs) to properly understand the new Australian Transfer Pricing (TP) rules, assess...more

PA Short Notes - March 2015

..In January, the PA Department of Revenue advised the tax community that it had - in November - joined the Multistate Tax Commission's corporate tax audit program, in order to increase the effectiveness and efficiency of PA...more

Tax Policy Update

NUMBER OF THE WEEK: 8 percent. The increase in the total amount of corporate profits kept abroad, according to the latest analysis of securities filings by Bloomberg News. The report confirms what U.S. companies have as much...more

Let the Training Begin: MTC Transfer Pricing Audits Draw Near

Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state...more

Massachusetts Tax Developments - A Reed Smith Quarterly Update: March 2015

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look at the most recent developments in Massachusetts corporate tax, sales and use tax, and tax administration; and discuss some...more

Supreme Court Decides Alabama Department of Revenue v. CSX Transportation, Inc.

On March 4, 2015, the Supreme Court decided Alabama Department of Revenue v. CSX Transportation, Inc., No. 13-553, holding that a rail carrier can prove discrimination under the Railroad Revitalization and Regulation Reform...more

Tax Policy Update

NUMBER OF THE WEEK: $42,268. The projected average taxable income of all tax returns in 2015, according to the Joint Committee on Taxation’s Feb. 27 report on “Fairness and Tax Policy.” The report also projects that the top...more

Welcome Tax Measures Announced at the PDAC 2015 Convention

On Sunday March 1, 2015, the Honourable Joe Oliver, Federal Minister of Finance addressed the Prospectors & Developers Association of Canada (“PDAC”) at the annual PDAC Convention in Toronto and announced certain proposals...more

Restructurings and Distressed Investing — Planning the Perfect Exit

Investors must address several key issues at the outset of a restructuring to smooth the path to a successful realisation of their investment. The classic image of a restructuring situation is of the critically ill...more

Locke Lord QuickStudy: Choice of Entity Considerations

Starting a business can be a daunting but rewarding challenge. One of the key decisions at the early stages of a new business is how to structure your business – i.e., what legal entity to form in order to carry on your...more

Inside the New York Budget Bill: Guidance Released Regarding Transitional Compliance and Qualified New York Manufacturers

On March 31, 2014, Governor Andrew Cuomo signed into law a budget bill containing major corporate tax reform. That new law resulted in significant changes for many corporate taxpayers, including a complete repeal of Article...more

ConAgra Brands; Taxpayer Loss in First Post-Gore Decision Signals More Challenges for Intercompany Transactions in Maryland

The Maryland Tax Court recently issued its decision in ConAgra Brands Inc. v. Comptroller of the Treasury, 09-IN-OO-0150 (Md. Tax Ct., Feb. 24, 2015). The case involved the Comptroller’s assertion of nexus over ConAgra...more

Pennsylvania Goes to Market: State Applies Source Taxation All the Way Home

On December 12, 2014, the Pennsylvania Department of Revenue (DOR) issued Information Notice Corporation Taxes 2014-1 (Notice). The Notice provides guidance for taxpayers in understanding Pennsylvania’s new market-based...more

Tips and Traps Regarding the Statute of Limitations and Signing Statute Waivers

As you end your telephone conversation with the revenue examiner, you think to yourself, “Thank goodness, this one is finally over!” The audit of your biggest client started over three years ago, and has seemingly dragged on...more

Real Estate Acquisitions in Japan

Interest in acquiring Japanese real estate, such as hotels, office buildings and retail complexes, is increasing due to Abenomics and the depreciation of the yen against major currencies. Japan expects to have a robust estate...more

India Shows a Way

Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a...more

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect...more

China's Tax Administration Issues New Rules Governing Taxation of Offshore Indirect Transfers

On February 3, 2015, the PRC State Administration of Taxation (“SAT”) released the Announcement of SAT Concerning Several Matters Relating to Corporate Income Tax on Indirect Transfer of Properties by Non-tax Resident...more

IRS Ruling Permits Inclusion of “Friendly PCs” in Consolidated Federal Income Tax Returns

On December 19, 2014, the Internal Revenue Service (“IRS”) issued a private letter ruling (the “Ruling”) allowing corporations that manage physician practices through a so-called “friendly physician” arrangement to treat the...more

Section 162(m) Compliance Alert

Compensation paid by a publicly-traded corporation to its Chief Executive Officer and three other highest compensated officers (other than the Principal Financial Officer) is generally not tax deductible to the extent the...more

Is a Distribution of Previously Taxed Income “Exempt from Tax”?

A U.S. shareholder of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of the CFC’s subpart F income and/or the amount determined under Section 956 with respect to such...more

ALJ: New York NOL Deduction Does Not Apply When Tax Is Not Paid on Income Base

A New York State Division of Tax Appeals administrative law judge (ALJ) recently determined that a banking corporation was not required to hypothetically use a net operating loss (NOL) deduction to decrease its entire net...more

Tax Policy Update

NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance...more

More Tough Talk on Cracking Down on Offshore Activity

In what is becoming a popular refrain, we are continuing to hear tough talk by government officials on cracking down on offshore activity. The most recent target is once again corporate inversions. ...more

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