Mondaq USA: Tax
Morrison & Foerster LLP
The Massachusetts Appellate Tax Board recently vacated, on its own motion, a previous decision in favor of the Commissioner of Revenue and ruled that a Massachusetts-based company
Ogletree, Deakins, Nash, Smoak & Stewart
With one exception addressed below, the TCJA generally disallows any employer deduction for providing qualified parking to employees.
Day Pitney LLP
On April 17, the IRS issued proposed regulations that provide new guidance for investors seeking to invest in qualified opportunity funds (each, a QOF), a new investment program designed to incentivize long-term investment ...
Morrison & Foerster LLP
Welcome to the latest issue of New York Tax Insights.
Dickinson Wright PLLC
With the 2018 deadline for filing of individual income tax returns just around the corner, taxpayers should be aware of the recent announcement by the IRS of expanded relief from penalties for individuals whose 2018...
Reinhart Boerner Van Deuren s.c.
Attorney Robert J. Misey, Jr. offers advice published in the December/January (2018) Journal of Tax Practice & Procedure
Ropes & Gray LLP
On March 21, 2019, the IRS announced it is temporarily suspending two revenue rulings addressing tax-free spinoffs.
Proskauer Rose LLP
On March 15, 2019, the U.S. Court of Appeals for the Seventh Circuit held in Gaylor v. Mnuchin that the tax exemption for "ministers of the gospel" (defined below) under Section 107(2)
Moritt, Hock & Hamroff LLP
Rev. Rul. 57-464 and Rev. Rul. 57-492 have recently been suspended pending completion of a study by the Treasury Department and Internal Revenue Service concerning the five-year,
Mayer Brown
As previously discussed on this blog, Maryland, in 2017, become the first state in the county to offer an income tax credit for energy storage systems and, to our knowledge,
Kramer Levin Naftalis & Frankel LLP
As part of the 2020 budget, the New York State Senate and Assembly enacted new revenue legislation, which included an increase to New York State's transfer tax and mansion tax on transfers
Ruchelman PLLC
Code ง59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities ...
Ruchelman PLLC
The U.S. Federal deficit is expected to reach $1 trillion in 2019. Meanwhile, a hedge fund billionaire recently purchased a New York City condominium ...
Dickinson Wright PLLC
On March 28, 2019, U.S. Senate Finance Committee Chairman Chuck Grassley (R-IA) and Senator Ron Wyden (D-OR) introduced new tax legislation referred to as the Taxpayer First Act of 2019.
Ropes & Gray LLP
In an alarming development for some private equity funds, the Court of Justice of the European Union (the CJEU) has issued two judgments in the combined N Luxembourg 1 (Case C-115/16),
Ruchelman PLLC
Nothing is certain in this world, except death and taxes – and even taxes are subject to change.
Ruchelman PLLC
When foreign corporations have certain activities in the U.S., the question often arises as to whether a taxable presence exists in the U.S. for Federal income tax purposes.
Arnold & Porter
The US Internal Revenue Service and the US Department of Treasury recently released proposed regulations that may provide relief to individual US Shareholders of "controlled foreign corporations" ...
Jeffer Mangels Butler & Mitchell LLP
Different rates and withholding amounts generally apply to these two categories of income, as described below.
Duff and Phelps
On March 1, 2019, the APMA program announced the introduction of a new Excel-based model which taxpayers that are seeking an APA may be required to complete as part of the APA process.
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Ruchelman PLLC
On August 8, 2018, the I.R.S. issued much-awaited proposed regulations under new Code ง199A, which was added by the 2017 Tax Cuts and Jobs Act. The provision was initially discussed in detail in our February 2018 edition.
Duane Morris LLP
In 2014, Elon Musk announced that he was "open-sourcing" Tesla's patents.
Jones Day
A recent written auditor request indicates an aggressive position and differing treatment on previously exempt Illinois business-to-business property.
Womble Bond Dickinson
Were the Beatles still recording today, they might have to add this verse to Taxman.
Milbank LLP
Two years have passed since Treasury and the IRS first announced that they were working on guidance relating to the basis of grantor trust assets at death.
If you're a fund manager of a partnership investing in the United States, you need to prepare for new audit rules enacted by the IRS.
Fenwick & West LLP
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts
Mayer Brown
The deduction for interest has been under some pressure lately. In particular, the Tax Cuts and Jobs Act (P.L. 115-97) recently amended Section 163(j) of the Internal Revenue Code of 1986 ...
Proskauer Rose LLP
The passthrough deduction provides a maximum effective rate of 29.6%.
Ropes & Gray LLP
On December 21, 2018, IRS and Treasury issued final regulations implementing the partnership audit regime (T.D. 9844).
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