Mondaq USA: Tax
Grant Thornton LLP
On Date 1, the CFC loaned Amount 1 to Parent. Amount 1 was outstanding on the last day of CFC's quarter including Date 1.
Grant Thornton LLP
A transfer of property may be treated as a Section 351 transaction even if it is followed by subsequent transfers of the property as part of a prearranged, integrated plan.
Anderson Kill
The new year is no longer "new," the tax season is no longer "taxing," we can now enjoy spring and reflect on its beginnings.
Grant Thornton LLP
Three types of payment generally relate to an NPC: (i) periodic payments, (ii) nonperiodic payments and (iii) termination payments.
Grant Thornton LLP
The IRS issued a revenue ruling (Rev. Rul. 2015-09) on May 5 that addressed certain corporate step transaction issues and revoked a prior revenue ruling with similar facts (Rev. Rul. 78-120).
Grant Thornton LLP
The IRS Large Business and International Division (LB&I) issued a directive instructing examiners to discontinue exam activity and not begin new activity related to certain expenditures to maintain, repair or improve cable network property.
Grant Thornton LLP
In Massachusetts Mutual Life Insurance Co. v. U.S, 2015 U.S. App. LEXIS 57 (Fed. Cir. 2015), the U.S. Court of Appeals for the Federal Court affirmed the deductibility of policyholder dividends under the recurring item exception.
Grant Thornton LLP
Indiana Governor Mike Pence has signed several bills that significantly change elements of the Indiana income and sales tax laws.
Reed Smith
On March 19, 2015, Regency appealed the ATB's decision with the Massachusetts Appeals Court. Subsequently, Regency filed an application for Direct Appellate Review.
Grant Thornton LLP
The South Carolina Department of Revenue has issued a draft revenue ruling and revenue procedure relating to alternative apportionment that may have significant application to taxpayers.
Grant Thornton LLP
The taxpayers, a married couple residing in Howard County, Maryland, held an ownership interest in a federal S corporation providing nationwide health care services.
McDermott Will & Emery
On April 30, 2015, out-of-state professional football players earned victories against the City of Cleveland, Ohio.
Caplin & Drysdale
On May 20, 2015, the Treasury Department released five proposed changes to the U.S. Model Income Tax Treaty (the U.S. Model).
McDermott Will & Emery
The Massachusetts Department of Revenue (DOR) likely will have significantly less employees starting July 1, 2015, due to a Massachusetts employee retirement incentive program.
Reed Smith
This guidance takes the same position that the Massachusetts Department of Revenue allegedly took at audit against a telecommunications provider; a position that the taxpayer challenged at the Appellate Tax Board ("ATB").
Butler Snow LLP
On May 20, 2015, Tennessee Gov. Bill Haslam (R) signed into law the Revenue Modernization Act.
Bradley Arant Boult Cummings LLP
The U.S. Supreme Court issued its long-awaited decision in Comptroller of the Treasury of Maryland v. Wynne on May 18.
McDermott Will & Emery
On May 18, the U.S. Supreme Court issued its decision in Comptroller of the Treasury of Maryland v. Wynne.
McDermott Will & Emery
Illinois EDGE credits are discretionary income tax credits awarded by the Illinois Department of Commerce and Economic Opportunity (DCEO).
McGuireWoods LLP
With the May 31 deadline just around the corner, lawmakers have little choice but to coalesce around a two-month extension of highway funding authorization—setting the stage for a summer of tough negotiations.
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Fox Rothschild LLP
Last week, the IRS issued its "final" versions of the forms 1094-B, 1094-C, 1095-B and 1095-C along with instructions for the "B" forms and instructions for the "C" forms.
Duane Morris LLP
On June 18, 2014, the Internal Revenue Service (IRS) announced major changes in its offshore voluntary compliance programs.
Moodys Gartner Tax Law LLP
On May 7th, 2015, the US Treasury Department published its first quarter 2015 list of individuals who have chosen to expatriate and it was yet again an eye opening number.
Reed Smith
Last week, the Maryland General Assembly wrapped up its 2015 legislative session.
McDermott Will & Emery
FATCA went into effect on July 1, 2014, after numerous delays and multiple rounds of administrative guidance.
Mayer Brown
The US Internal Revenue Service (IRS) has published proposed regulations clarifying which activities generate "qualifying income" for a Master Limited Partnership (MLP).
Rumberger, Kirk & Caldwell, P.A.
The so-called sovereign citizen movement is a loose confederation of individuals with a collective belief that government, at essentially all levels, is involved in a conspiracy to deprive them of property and essential rights.
Holland & Knight
The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the OVDP.
Fox Rothschild LLP
Section 382 provides a limitation on change of control transactions involving loss corporations, i.e., target corporations with net operating loss carryovers or certain built-in losses.
Virtual currency developments continue to emerge, including state tax guidance, a court decision on deductibility of losses, and the Uniform Fiduciary Access to Digital Assets Act (the "Act").
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