News & Analysis as of

Business Organization Administrative Agency Tax

Read Business Organization updates, alerts, news, and legal analysis from leading lawyers and law firms:

House Tax Bill Would Fundamentally Change Executive Compensation and Employee Benefit Practices

by Morrison & Foerster LLP on

On November 2, 2017, the House Ways and Means Committee unveiled the Tax Cuts and Jobs Act (the “Bill”), which, if enacted, could dramatically impact certain aspects of executive compensation and employee benefit issues. The...more

Anti-Inversion Regulations Held to Violate Administrative Procedure Act

by King & Spalding on

On September 29, 2017, the United States District Court for the Western District of Texas struck down a 2016 temporary regulation designed to limit corporate inversions(the “Rule”). Rule was simultaneously issued as a...more

The Law of Ukraine “On Amending Certain Legislative Acts of Ukraine regarding Use of Seals by Legal Entities and Individual...

by Dentons on

On 19 July 2017, comes into force the Law of Ukraine “On Amending Certain Legislative Acts of Ukraine regarding Use of Seals by Legal Entities and Individual Entrepreneurs” dated 23 March 2017. The Law stipulates that the...more

The Law of Ukraine “On Amending Certain Legislative Acts of Ukraine regarding Use of Seals by Legal Entities and Individual...

by Dentons on

On 19 July 2017, the Law of Ukraine “On Amending Certain Legislative Acts of Ukraine regarding Use of Seals by Legal Entities and Individual Entrepreneurs” dated 23 March 2017 comes into force. The Law stipulates that the...more

The Taxpayer Transparency And Fairness Act Is Anything But

by Allen Matkins on

Recently, I wrote about the stealth with which the California legislature enacted AB 102, which it ironically named the Taxpayer Transparency and Fairness Act of 2017. Having been birthed in opacity, AB 102 will operate with...more

IRS Reissues Proposed Regulations for Centralized Partnership Audit Regime

by Morrison & Foerster LLP on

The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more

Swart's Athwart California's Taxation of Out-of-State Corporations

by Nossaman LLP on

The California Franchise Tax Board (“FTB”) started 2017 with a setback as the Court of Appeal for the Fifth Appellate District held in Swart Enterprises, Inc. v. Franchise Tax Board that the FTB could not impose California’s...more

MoFo New York Tax Insights - Volume 8, Issue 1

by Morrison & Foerster LLP on

The Top 10 New York Tax Highlights of 2016 - It’s the New Year, and before we begin afresh, we look back at this past year with our list of the Top 10 New York tax highlights of 2016. 1. The New York State Tax...more

“But I Didn’t Know” – Protecting Yourself from Responsible Person Status

by Farrell Fritz, P.C. on

A couple of weeks ago, we considered a situation in which an unscrupulous partner (perhaps in cahoots with an IRS agent) tried to stick one of their partners with the federal employment taxes owed by their failing business....more

MoFo New York Tax Insights - Volume 7, Issue 10

by Morrison & Foerster LLP on

Recent unpublished NYC Department of Finance Letter Rulings - We have obtained under the Freedom of Information Law several Finance Letter Rulings of interest, most involving the New York City real property transfer tax,...more

Maryland Tax Court Overturns Comptroller's Policy of Limiting Subtraction for Interest Received on Federal Obligations

by Reed Smith on

The Maryland Tax Court recently ruled that a bank was entitled to deduct all of its interest received with respect to federal obligations for Maryland corporate income tax purposes, thereby generating net operating losses...more

MoFo New York Tax Insights - Volume 7, Issue 8

by Morrison & Foerster LLP on

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

MoFo New York Tax Insights - Volume 7, Issue 7

by Morrison & Foerster LLP on

ALJ holds NYS Real Estate Transfer Tax Cannot Be Imposed on Sale of 45% Membership Interest in LLC - In an issue of first impression under the New York State real estate transfer tax, a New York State Administrative Law...more

MoFo New York Tax Insights - Volume 7, Issue 6

by Morrison & Foerster LLP on

New York City Tribunal Rejects City’s Attempt To Forcibly Combine Bank And Its Mortgage Subsidiary - The New York City Tax Appeals Tribunal, affirming a determination of the Chief Administrative Law Judge, has held that...more

New York City Tribunal Rejects City’s Attempt to Forcibly Combine Bank and Its Mortgage Subsidiary

by Morrison & Foerster LLP on

The New York City Tax Appeals Tribunal, affirming a determination of an Administrative Law Judge, has held that Astoria Bank, which engaged in a banking business in New York City, was not required to include in its combined...more

MoFo New York Tax Insights - Volume 7, Issue 5

by Morrison & Foerster LLP on

Retroactive Application Of 2010 Statutory Amendment Permitted By Tribunal - Reversing the decision of an Administrative Law Judge, the New York State Tax Appeals Tribunal has upheld the constitutionality of retroactively...more

MoFo New York Tax Insights - Volume 6, Issue 12

by Morrison & Foerster LLP on

NYC Tribunal Rejects Claim That First Amendment Requires Use of Audience Factor for Sourcing Receipts from Credit Ratings - The New York City Tax Appeals Tribunal, reversing an Administrative Law Judge decision, has held...more

"Congress Overhauls Partnership Audit and Litigation Procedures"

On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more

Conflating tax law and trust law: The strange case of Ciampa v. Bank of America.

by Charles E. Rounds, Jr. on

Under the Internal Revenue Code, an Individual Retirement Account (IRA) may be a trust. See 26 U.S. Code § 408(a). Or it may be a custodianship. See sub-section (h) to §408. Here is sub-section (h) verbatim: FOR PURPOSES...more

Focus on Tax Strategies & Developments - October 2015

by McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

MoFo New York Tax Insights - Volume 6, Issue 10

by Morrison & Foerster LLP on

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

Altera: Tax Court Invalidates Section 482 Regulation on Administrative Law Grounds

by McDermott Will & Emery on

In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm’s-length...more

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

"Tax Court Invalidates Stock-Based Compensation Amendment in Altera"

On July 27, 2015, the U.S. Tax Court, in Altera Corp. and Subsidiaries v. Commissioner, 145 T.C. No. 3, invalidated a 2003 amendment to Treas. Reg. §1.482-7(d)(2) (2003 Amendment) that required controlled participants in a...more

Department of Justice Reprioritizes Asset Seizure in Structuring Cases But Risks Remain

by Williams Mullen on

On December 23, 2014, the United States Attorney for the Eastern District of North Carolina filed a Complaint for Forfeiture In Rem seeking to forfeit $107,702.66 belonging to Lyndon McLellan, the owner of L&M Convenient Mart...more

209 Results
|
View per page
Page: of 9
Cybersecurity

Follow Business Organization Updates on:

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.