News & Analysis as of

Non-Taxable Income

A Time to Remember that Employer-Provider Data Breach Benefits are not Taxable

by Snell & Wilmer on

Hardly a week goes by without another announcement of a high-profile data security breach. The list of data breaches impacting high-profile employers and their employees just in 2017 is long...more

Golly Gee—the U.S. Tax Court Ruled That the Cost of a Taxpayer's Microsoft Xbox 360 and a Nintendo Wii Used by His Children Did...

by Garvey Schubert Barer on

In 2015, the U.S. Tax Court issued its ruling in the case of David W. Laudon v. Commissioner, TC Summary Option 2015-54 (2015). The case may not raise or even resolve any novel tax issues, but it reminds us of what is...more

Creating Non-Taxed “Previously Taxed Income”: The Ultimate Pre-Immigration Strategy

by Bilzin Sumberg on

According to recent statistics, immigrants and their U.S.-born children now number approximately 84.3 million people, or 27% of the overall U.S. population. The countries from which the largest numbers of these individuals...more

Texas Appeals Court Affirms Summary Judgment For Texas Comptroller In Risk Pool Row

by Carlton Fields on

A Texas appeals court affirmed a summary judgment that rejected an attempt by two insurers to recover more than $1.1 million for taxes, penalties, and interest on certain reinsurance agreements. Argonaut Insurance Company and...more

Trusts Find Shelter from State Taxes in State Courts

by BakerHostetler on

In two recent cases, taxpayers have successfully challenged state taxation of trust income on the basis that the taxing states had a minimal connection to the trust. In The Kimberly Rice Kaestner 1992 Family Trust v. North...more

Global Tax News - July 2015

by DLA Piper on

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

Frequent Flyer Miles–Sometimes Taxable, Sometimes Not

by Charles (Chuck) Rubin on

A recent Tax Court case adds to the rules that now exist whether frequent flyer miles will be considered taxable income. Below is a summary. 1. The general rule under Announcement 2002-18 is that awarded miles, whether...more

IRS Changes Position on Non-Taxable IRA Rollover Contributions

by Akerman LLP on

The U.S. Tax Court recently decided that the one-per-year IRA rollover limitation in 26 U.S.C. § 408(d)(3)(B) applies in the aggregate to all of the taxpayer’s IRA accounts rather than separately to each of a taxpayer’s IRA...more

Sutherland SALT Shaker: August 2013 Digest

In this issue: - No Expressions of Goodwill from Arizona Department of Revenue - California Court of Appeal: ITFA Doesn’t Make the CUT - Round We Go: Indiana Denies Taxpayer’s Intercompany “Residual...more

For Private Equity Investors, Section 1202 May Be Worth Another Look

by McDermott Will & Emery on

Included in the American Taxpayer Relief Act of 2012 (ATRA) are provisions that extended some of the more significant benefits of Internal Revenue Code Section 1202, the Code provision that permits eligible noncorporate...more

Tax Topics: Restrictive Covenants — The Final Chapter (For Now)— Part I

by Dentons on

This article discusses proposed legislation dealing with the taxation of restrictive covenants. Due to its length, it is divided into two parts. Part I addresses the history, basic inclusion rules, tax treatment to the...more

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