Mondaq USA: Tax
Grant Thornton LLP
Delaware is currently offering an unclaimed property voluntary disclosure program (VDA) through September 30, 2014.
Fox Rothschild LLP
There have reported to have been approximately 15 major inversion transactions engaged in by U.S. multinationals this year.
Grant Thornton LLP
Tax writers have begun negotiating in earnest to extend the 50-plus tax provisions that expired at the end of 2013.
Grant Thornton LLP
Congress and the administration are under increasing pressure to stem the flow of recent inversion transactions.
Grant Thornton LLP
The Tax Court recently ruled that losses a husband and wife incurred from their interest in two Subchapter S corporations weren’t suspended passive activity losses.
Bradley Arant Boult Cummings LLP
In 2012, Dr. Robert A. Robicheaux, issued a report titled "Estimates of Alabama Losses Due to E-Commerce.
Bradley Arant Boult Cummings LLP
The Alabama Department of Revenue's Administrative Law Division issued a ruling that will likely send shock waves to photographers across the state.
Ropes & Gray LLP
The IRS provided official notice to taxpayers of their intention to issue regulations limiting taxpayers’ ability to benefit from undertaking "inversion transactions."
Grant Thornton LLP
The Tax Court held that both the partners and the partnership had zero tax basis in personal promissory notes contributed to the partnership.
Grant Thornton LLP
In a chief counsel advice memorandum the IRS considered whether interest that is accrued but not paid is "United States property" under Section 956.
Grant Thornton LLP
The IRS ruled that a corporation that provides products and services to the pharmaceutical industry was engaged in a qualified trade or business for purposes of Section 1202.
Grant Thornton LLP
In private letter ruling 201436033, the IRS considered a transaction that involved the back-to-back distributions of a real estate investment trust.
Grant Thornton LLP
Lawmakers have just a few legislative days remaining before they break again for the final stretch of campaigning ahead of the November midterm elections.
Mayer Brown
Following weeks of anticipation and speculation about administrative guidance on corporate inversions, the Internal Revenue Service ("IRS") and the Treasury Department ("Treasury") released Notice 2014-52 ("Notice") on September 22, 2014, describing new regulations to be issued by the government to curtail inversion transactions.
Grant Thornton LLP
The IRS issued final regulations (T.D. 9691) on Aug. 27, 2014, related to the application of Section 1092 and the regulations thereunder to debt instruments.
Grant Thornton LLP
The IRS issued Rev. Proc. 2014-51, which supersedes Rev. Proc. 2011-16, concerning the treatment of safe harbors for purposes of determining real estate investment trust qualifications.
Grant Thornton LLP
The IRS addressed a reorganization in which some members of a consolidated group were under Chapter 11 bankruptcy protection and some members were not.
Grant Thornton LLP
Certain payments made by a lessee to reimburse the lessor for tenant improvement costs above an agreed-upon allowance were not rental income to the lessor.
Jones Day
On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52.
McDermott Will & Emery
On September 17, 2014, the U.S. Tax Court issued its first opinion regarding the discovery of electronically stored information (ESI). In Dynamo Holdings, Ltd. vs. Commissioner, 143 T.C. No. 9 (Sept. 17, 2014), the Tax Court permitted a taxpayer to use "predictive coding" as a first-level review of a large pool of documents.
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Grant Thornton LLP
The IRS issued the 2014 optional standard mileage rates used to calculate the deductible costs of operating an automobile for business, charitable, medical or moving purposes.
Ostrow Reisin Berk & Abrams
Cash contributions are fundamental sources of revenue for your organization; however, do not underestimate the importance and value of receiving gifts-in-kind.
Holland & Knight
The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the OVDP.
Duane Morris LLP
On June 18, 2014, the Internal Revenue Service (IRS) announced major changes in its offshore voluntary compliance programs.
Reed Smith
Overseas Shipping Group ("Overseas") recently sued its former attorneys, a prominent New York-based law firm, for legal malpractice in drafting credit agreements that resulted in the company incurring an estimated $463 million in tax liability.
Dentons (US)
On December 30, 2013, the US Treasury Department (the "IRS") published a package of proposed, temporary, and final regulations relating to Passive Foreign Investment Companies ("PFICs") and their shareholders.
McGuireWoods LLP
On January 27, 2014, the Internal Revenue Service published Revenue Procedure 2014-18.
Pepper Hamilton LLP
It has been estimated that annual gift card sales have reached approximately $110 billion as a result of an increase in gift card offerings from financial services firms.
Mitchell Silberberg & Knupp LLP
Background. The law is well settled that the recipient of a gift or bequest is not required to pay income taxes when he or she receives the gift or bequest.
Blank Rome LLP
With the recent expansion of Blank Rome’s Los Angeles office and the addition of a San Francisco office, the Private Client Group has planted its flag on the West Coast.
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