Mondaq USA: Tax
Shearman & Sterling LLP
The Treasury Department and the IRS released Notice 2015-79 (the "2015 Notice") on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by them on September 22, 2014.
Effective for tax years beginning after December 31, 2017, any additional tax or penalties resulting from a partnership audit will be assessed and collected at the partnership level in the year the audit is completed.
The McLane Law Firm
Recently enacted House Bill 2 includes a tax amnesty plan for all New Hampshire taxes collected by the Department of Revenue Administration.
Shearman & Sterling LLP
In September 2003, Petitioner sold his cellular telephone business, West Side, a C corporation incorporated in Ohio, to Nob Hill, Inc., a Cayman Islands company and affiliate of Fortrend, for $35 million dollars.
Shearman & Sterling LLP
On October 15, 2015, the IRS issued a proposed revenue procedure (Notice 2015-22)52 that would update Rev. Proc. 87-84...
Shearman & Sterling LLP
On September 11, 2015, the IRS, responding to the Tax Court's request for suggested revisions to the Tax Court's Rules of Practice and Procedure, proposed changes to help improve tax court procedures...
Shearman & Sterling LLP
On September 15, 2015, the United States District Court, District of Connecticut rejected most of the Government's challenges to privilege claims asserted by General Electric Company ("GE").
Shearman & Sterling LLP
As previously reported, on July 8, 2015, the IRS issued Notice 2015-47 and Notice 2015-48, which designated "basket option" transactions as listed transactions and "basket contract"...
Shearman & Sterling LLP
These summonses permit the IRS to seek records of the Belize Banks' correspondent accounts at Bank of America, N.A. and Citibank, N.A.
McGuireWoods LLP
NUMBER OF THE WEEK: 15 - The number of legislative days left until Dec. 11, when Congress must pass an omnibus spending bill to avert a government shutdown.
Mayer Brown
The efforts of the US Internal Revenue Service (the "IRS") to broadly challenge the purported federal income tax consequences of barrier and basket options has been gathering steam over the past few years.
Jones Day
On October 20, 2015, the New York Court of Appeals issued a ruling that could prove important to corporate counsel as they provide advice on tax positions.
Day Pitney LLP
On November 18, the New Jersey Department of the Treasury announced that it has issued letters to Jersey City, Dunellen and Elizabeth informing those municipalities that the state will conduct an investigation to determine whether to order a revaluation of properties within those towns for property tax purposes.
Grant Thornton LLP
The EDGE Tax Credit is Illinois' main incentive program to attract and keep businesses in the state
Kaye Scholer LLP
Partnerships with more than 10 partners are subject to audit provisions that were enacted under the "Tax Equity and Fiscal Responsibility Act of 1982" (TEFRA).
Reed Smith
In a 5Ė2 decision, the Pennsylvania Commonwealth Court in an en banc panel has held that Pennsylvania's NOL cap violates the Uniformity Clause of the Pennsylvania Constitution, and granted the taxpayer (Nextel Communications of the Mid-Atlantic, Inc., or "Nextel") the right to deduct its NOLs without regard to the statutory NOL cap, which resulted in a refund to Nextel.
Stoll Keenon Ogden PLLC
The Taxpayers appealed the KDOR's denial of their refund claims to the KBTA, which ruled in favor of the KDOR.
McDermott Will & Emery
The Regulation reflects recent statutory changes made to the apportionment formulas for both non-airline and airline transportation services. See 35 ILCS 5/304(d).
McDermott Will & Emery
Yesterday, the City of Chicago Department of Finance published an Information Bulletin that provides additional guidance on the Personal Property Lease Transaction Tax and extends a new Voluntary Disclosure Agreement offer to providers and customers.
Grant Thornton LLP
On October 27, 2015, the Michigan Court of Appeals held in a published decision that the purchase and use of certain cloud computing services by a Michigan insurer were not subject to Michigan use tax.
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Troutman Sanders LLP
Under current law, taxpayers who have mortgage debt canceled or forgiven after 2014 may be required to pay taxes on that amount as taxable income.
The McLane Law Firm
Prior to the current Massachusetts estate tax system, Massachusetts was a "sponge tax" state, where the Massachusetts estate tax was directly linked to the federal estate tax.
Grant Thornton LLP
Oklahoma has enacted legislation authorizing and directing the Oklahoma Tax Commission to administer a tax amnesty program, termed a "voluntary compliance initiative," from September 14 to November 13, 2015.
Womble Carlyle
Last week, President Obama signed H.R. 1314, the Bipartisan Budget Act of 2015, which dramatically changes the manner in which partnerships are audited and taxed by the IRS.
Grant Thornton LLP
On April 27, Missouri enacted legislation authorizing the Missouri Department of Revenue to administer a tax amnesty program from September 1 to November 30, 2015.
Kaye Scholer LLP
G20 finance ministers last week finally approved the wide-ranging "BEPS" reforms to the international tax system.
Withers LLP
On June 4, 2015, following extensive negotiations between the legislature and the Governor's office, the Connecticut General Assembly passed H.B. 7061 (the "Budget Bill") into law.
Fox Rothschild LLP
The Internal Revenue Service (IRS) has issued final regulations that may increase the amount of the gift tax exemption available to a surviving spouse.
Withers LLP
The favoured tax status of foreigners planning not to stay in the UK on a long term basis (so called 'non-doms') became a hot topic in the run up to the UK General Election in May 2015, and one of George Osborne's early acts as Chancellor was to announce changes to the regime.
Fisher & Phillips LLP
One of the new Affordable Care Act (ACA) requirements imposed on employers is the obligation to report employee group health plan coverage information to the IRS and employees on Forms 1094-C and 1095-C.
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