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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

The Revival of North Carolina General Assembly Special Sessions and Why They Matter

by Ward and Smith, P.A. on

Brief History of Special Sessions - In odd numbered years, after the North Carolina General Assembly adjourns its Long Session, the body typically abstains from lawmaking through the commencement of the Short Session the...more

European Union adopts new Directive to better resolve double taxation disputes

by DLA Piper on

The Council of the European Union adopted the Tax Dispute Resolution Mechanism Directive on 10 October 2017. Whereas currently the scope for mandatory arbitration in dispute resolution is limited to transfer pricing...more

What REITs Need to Know About the New Partnership Audit Rules

by Goodwin on

The Bipartisan Budget Act of 2015 fundamentally changes the rules and procedures governing IRS audits of partnerships for taxable years beginning on or after January 1, 2018. These new rules are contained in new Sections...more

2018 Cost-of-Living Adjustments on IRS Benefit and Contribution Limits

On October 19, 2017, the Internal Revenue Service (IRS) announced the cost-of-living adjustments impacting tax-qualified pension plans for 2018. The increase in the cost-of-living index met the statutory thresholds that...more

What To Avoid In Hiring Plan Providers As 401(k) Fiduciaries

by Ary Rosenbaum on

A plan sponsor has so many things to do in running a business that they often forget that as a 401(k) plan sponsor, they are also a plan fiduciary. Being a plan fiduciary requires the highest duty of care in equity and law....more

Tax Plan in Coalition Agreement Cabinet Rutte III (Dutch)

by Dentons on

Tax aspects of the 2017-2021 Government Agreement for Business - On October 10, the Cabinet Rutte III presented its government agreement for the next 4 years. Hereafter we discuss the most eye-catching fiscal aspects of...more

Is a Series LLC Right for Your Business?

by Mintz Levin on

The Series limited liability company (the “Series LLC”) is more nuanced than an ordinary limited liability company, and for the right user, it provides flexibility that will streamline administration better than other...more

Global In-House Centers in India, v2.0

GICs in India are evolving from cost-saving platforms into Innovation Centers for emerging digital technologies that can provide a competitive advantage. Recent years have seen a resurgence of interest in GICs in India...more

Tax planning for private corporations and their shareholders - converting income into capital gains

by Dentons on

On October 19, 2017, the Department of Finance Canada issued a news release advising that it will not move ahead with proposed measures intended to target the conversion of income into capital gains. The announcement is the...more

A Summary of the Proposed Partnership Audit Regulations

by Davis Brown Law Firm on

This blog post is intended to identify the most material aspects of the proposed regulations the IRS has introduced to implement the BBA partnership audit rules, and provide guidance on what actions a partnership should...more

The Acquisition and Leveraged Finance Review – US

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

Pennsylvania Supreme Court Finds Flat-Dollar NOL Cap Unconstitutional, But Upholds Percentage Cap

The Pennsylvania Supreme Court held that the state’s flat $3 million cap on net operating loss (NOL) carryforwards violates the state constitution’s Uniformity Clause. Unlike the lower court, however, the Supreme Court left...more

The Acquisition and Leveraged Finance Review – Russia

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

The Acquisition and Leveraged Finance Review – Spain

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

The Acquisition and Leveraged Finance Review – Germany

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

The Acquisition and Leveraged Finance Review – England and Wales

by Latham & Watkins LLP on

Acquisition and leveraged finance is a fascinating area for lawyers, both inherently and because of its potential for complexity arising out of the requirements of the acquisition process, cross-border issues, regulation and...more

ESOPs: An Alternative Exit Strategy for Family-Owned Businesses

One of the most difficult challenges for owners of family-owned businesses is finding a way to turn their equity in the business into cash. Also, after putting years of hard work into a business, owners often have a desire...more

Taxation of private corporations and their shareholders

by Dentons on

On July 18, 2017, the Department of Finance Canada introduced draft legislative proposals impacting private corporations and their shareholders. A 75-day consultation period was provided with a deadline for taxpayer...more

New Guidance Sheds More Light on Italian Carried Interest Tax

by McDermott Will & Emery on

Following the approval of the new rules regarding taxation of carried interest proceeds enacted with Law Decree No. 50/2017 (Decree), the Italian Tax Authorities issued specific guidelines with Circular Letter No. 25/E, dated...more

Recent Rulings on “Family Limited Liability Entity” Election Create Traps for the Unwary

Although every LLC, limited partnership or other pass-through entity doing business in Alabama, and even those simply organized under Alabama law, are subject to an annual business privilege tax (BPT), certain entities can...more

IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)

by Proskauer - Tax Talks on

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more

Groundbreaking—IRS makes things complicated

Employers who adhere to certain IRS guidelines may face much lower indemnity payments for employees who traveled for work pre-injury - Myres v. Strom Aviation, Inc. (16-558) - In companies where employees regularly...more

End and refund of the French 3% tax on distributions

by White & Case LLP on

The French Constitutional Court rules that the 3% contribution on distributions is unconstitutional - On 6 October, 2017, the French Constitutional Court, in its decision (n°2017-660 QPC), held that the 3% contribution on...more

IRS Proposes Update and Streamlining of Public Approval Under TEFRA

by Miles & Stockbridge P.C. on

The Internal Revenue Service (the “IRS”) and The U.S. Department of the Treasury (the “Treasury”) proposed regulations on September 28, 2017 to update and streamline the public approval requirement applicable to tax-exempt...more

Extending an Olive Branch: IRS Issues Ruling Providing Taxpayer Relief for Late Election of Rev. Proc. 2011-29 Safe Harbor

The Internal Revenue Service (Service) issued PLR 201739003 on September 29, 2017, in which it granted an extension to a taxpayer that failed to timely file for the safe-harbor election provided in Rev. Proc. 2011-29, 2011-1...more

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