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Dividends Tax Returns

Pillsbury - SeeSalt Blog

Carveouts Count! Taxpayer Wins New Mexico Statutory Carveout Issue Regarding Unity

The New Mexico Court of Appeals has held that a multinational oil and gas production company did not constitute a “unitary corporation” with its foreign subsidiaries, pursuant to statutory carveout language regarding the term...more

Rivkin Radler LLP

New York Can Be Stingy Giving Credit – Resident Tax Credit, That Is

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The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more

Stinson LLP

Missouri Revenue Officials Disallow REIT Dividend Deductions

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Missouri law allows taxpayer corporations to reduce their Missouri-taxable income by the amount of “corporate dividends from sources within Missouri.” The statute is said to be a legislative policy choice to encourage...more

Rivkin Radler LLP

Reasonable Compensation Meets The Principal Shareholder of a C Corp

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Double Tax- The shareholders of C corporations have long sought legitimate operational and transactional structures by which they may reduce the double tax hit that is realized when such a corporation distributes its...more

Eversheds Sutherland (US) LLP

New Jersey fixes “trapped dividend exclusion” problem

The New Jersey Division of Taxation issued a notice on November 5th solving the “trapped dividend exclusion” issue faced by many taxpayers as they prepared to file their first New Jersey combined Corporate Business Tax (CBT)...more

Skadden, Arps, Slate, Meagher & Flom LLP

Challenging Tax Cuts and Jobs Act Regulations and IRS Guidance

The Tax Cuts and Jobs Act (TCJA) brought sweeping changes to the U.S. international tax system. Along with those changes came substantial taxpayer uncertainty as to how the TCJA’s rules apply to their unique circumstances....more

Bilzin Sumberg

Cancellation of CFC Loans to US Shareholders – Should the Service Get a Second Bite at the Apple?

Bilzin Sumberg on

The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general rule, such as where a taxpayer files a false return or omits more than 25...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, Issue 10

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

Baker Donelson

Mississippi Court Rules Discriminatory Exclusion is Unconstitutional

Baker Donelson on

The Hinds County Chancery Court recently issued an opinion in AT&T Corp. v. Miss. Dep't of Revenue finding that Mississippi's dividend exclusion statute unlawfully discriminates against interstate commerce and is therefore...more

Butler Snow LLP

Hold The Phone! AT&T’s Constitutional Challenge To Mississippi’s Dividend Exclusion Statute Is Still Alive

Butler Snow LLP on

A Mississippi trial court has again found unconstitutional the state’s dividend exclusion statute, which disadvantages certain multistate taxpayers as compared to solely Mississippi taxpayers. This result comes from AT&T’s...more

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