Mondaq USA: Tax
Shearman & Sterling LLP
On October 13, 2016, the US Department of the Treasury and the Internal Revenue Service released final and temporary regulations under section 385 of the Internal Revenue Code...
Fox Rothschild LLP
Lee's book provides a detailed analysis of the international tax compliance regime imposed by the Foreign Account Tax Compliance Act (FATCA), and its impact on foreign financial institutions, withholding agents and U.S. citizens and residents with offshore bank accounts and investments.
Grant Thornton LLP
New final and temporary regulations under Section 385, addressing the treatment of related-party debt, significantly narrow parts of the controversial proposed regulations released in April.
Seyfarth Shaw LLP
On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues...
McDermott Will & Emery
On Monday, October 17, the Illinois Appellate Court issued another taxpayer-friendly opinion in an Illinois False Claims Act case alleging a failure to collect and remit sales tax on internet and catalog sales to customers in Illinois.
McDermott Will & Emery
Understanding the timing of a US Federal tax controversy is helpful in creating a sound and efficient strategy.
McDermott Will & Emery
The Supreme Court of the United States has been asked to hear an appeal in a case involving the circumstances in which retroactive tax legislation will be constitutional.
McDermott Will & Emery
After the highly publicized administrative lease transaction and amusement tax expansions in Chicago last year, more cities around the country are taking steps to impose transaction taxes...
The McLane Law Firm
For many New Hampshire business entities taxable as partnerships, including multi-member limited liability companies and general and limited partnerships, the possibility of an adverse IRS audit is a continuing nightmare.
Foley & Lardner
Both fund sponsors and investors will need to carefully evaluate the audit provisions of fund agreements and consider whether existing fund agreements should be amended.
McDermott Will & Emery
On October 13, 2016, the IRS released an LB&I International Practice Unit, providing guidance to IRS agents relating to the identification of foreign goodwill or going concern value...
Grant Thornton LLP
The California Franchise Tax Board (FTB) has recently issued guidance to clarify the rules for water's-edge filers with foreign affiliates...
Grant Thornton LLP
On July 22, 2016, the Texas Comptroller of Public Accounts issued a letter ruling addressing the proper apportionment of gross receipts from the sale of substantially all of the assets of a company located in Texas to an entity incorporated in Delaware.
Morrison & Foerster LLP
Halloween is just around the corner, and if the government doesn't issue the section 385 regulations soon, the references to those controversial regs and "trick or treat" in law firm client alerts will be overwhelming.
Grant Thornton LLP
The IRS has issued much anticipated guidance concerning disguised sales of property involving partnerships under Section 707 and the determination of whether an obligation is a recourse liability under Section 752.
Grant Thornton LLP
The JobsOhio Board of Directors recently has approved a Research and Development (R&D) Grant Program to provide support to R&D centers in Ohio.
Ostrow Reisin Berk & Abrams
The Personal Property Lease Protection Tax, or "Cloud Tax" as it is more commonly known, was implemented this year.
McDermott Will & Emery
Most tax cases are decided by the US Tax Court (Tax Court). The Tax Court issues two categories of opinions: (1) formally published dispositions; and (2) unpublished dispositions.
Stoll Keenon Ogden PLLC
The IRS has proposed new regulations that will substantially impact family-controlled entities.
Duane Morris LLP
On Oct. 7, 2016, the New Jersey legislature approved a bill that would eliminate the New Jersey estate tax by 2018.
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Saul Ewing LLP
I've written before about the new proposed Treasury Regulations under Section 2704 of the Internal Revenue Code.
Fox Rothschild LLP
News of the expected phase-out of New Jersey's estate tax — along with changes to federal estate tax laws in recent years — means that many New Jersey residents should consider simplifying their estate planning documents to eliminate outdated provisions designed to save state and federal estate taxes.
The case involved the appropriate burden of proof the Internal Revenue Service must meet when the IRS asserts a willful failure to file penalty for the Report of Foreign Bank and Financial Accounts.
Poyner Spruill LLP
​The IRS has proposed new rules that will require tax-exempt hospitals (and other tax-exempt entities) to review a variety of compensation arrangements to avoid unintended tax consequences.
A recent decision by the Israeli Supreme Court has cleared the way for FATCA implementation by lifting a temporary injunction on the disclosure of information to U.S. authorities under IGA.
Day Pitney LLP
On September 12, the Third Circuit Court of Appeals held that the United States District Court for the District of New Jersey erred in dismissing a suit against Jersey City challenging its ordinance which required the use of union labor on certain construction projects which were subject to property tax abatements.
McDermott Will & Emery
The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided.
Baker Newman Noyes
Several pieces of legislation signed into law during 2015 changed the due dates for certain taxpayers' Income Tax and Information Returns effective for taxable years beginning after December 31, 2015.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Uber, Lyft, and their competitors, offering handy apps, responsive drivers and competitive prices, are fast becoming a favored commuter option.
Day Pitney LLP
Many donors appreciate "thank-you" notes from charities as a polite gesture and do not realize they can be a key to a deduction.
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