Mondaq USA: Tax
McGuireWoods LLP
Last Tuesday’s midterm election results signaled major changes coming to Capitol Hill in 2015.
Proskauer Rose LLP
We last updated our readers in February 2014 on issues related to the disclosure and automatic exchange of financial information on an international basis.
Grant Thornton LLP
Republicans won a sweeping election victory last week, capturing the Senate and changing the landscape for tax legislation.
Grant Thornton LLP
Treasury officials said last week that the agency is still working on more guidance aimed at stemming the flow of U.S. companies reorganizing as foreign entities.
Reed Smith
This is a brief update on recent Pennsylvania tax developments.
Grant Thornton LLP
The IRS has issued guidance in Notice 2014-66 designed to allow expanded use of income annuities in Section 401(k) plans.
Grant Thornton LLP
The Tax Court has ruled in Brinkley v. Commissioner (T.C. Memo 2014-227) that a payment an employee received in excess of the fair market value of the stock he held was compensation instead of capital gain.
Grant Thornton LLP
The Large Business & International division (LB&I) has issued a directive (LB&I-04-0814-007) to examiners that provides guidance in determining whether a taxpayer’s method for allocating mixed service costs (MSC) to certain self-constructed tangible personal property is appropriate and should not be challenged.
Grant Thornton LLP
The IRS has released field attorney advice (FAA 20144201F) clarifying the ordering rules for alternative tax net operating losses.
Grant Thornton LLP
The IRS has issued proposed regulations (REG-151416-06) to revise regulations under Section 751(b) that have remained generally untouched since 1956.
Grant Thornton LLP
In a directive dated October 10, 2014, the North Carolina Department of Revenue announced a change in its policy regarding the apportionment and allocation of income by multistate partnerships.
Grant Thornton LLP
The Illinois Department of Revenue recently has released several private letter rulings (PLRs) and general information letters (GILs) which provide taxpayers with guidance on a variety of sales and use tax issues.
Morrison & Foerster LLP
In an interesting case involving the New York City Comptroller's authority to subpoena general corporation tax records from the New York City Department of Finance, a New York State Supreme Court judge has issued an order holding that the Department of Finance must turn over tax records
Reed Smith
This post is part of a series of posts discussing key issues in the Appellate Tax Board’s recent decision in Genentech, Inc. v. Commissioner. We previously reported on this decision in our prior post.
Grant Thornton LLP
The Large Business and International division of the IRS recently issued a directive to its examining agents providing guidance for examining bad debt deductions under Section 166.
Bradley Arant Boult Cummings LLP
Facts: The taxpayer is a provider of comprehensive and integrated technology solutions that involve transfers of hardware, software, and value-added services.
Reed Smith
On November 17, 2014, the Appellate Tax Board released its Findings of Fact and Report in Genentech v. Commissioner which held that a pharmaceutical company qualified as a "manufacturer" under Massachusetts law, and was required to apportion its corporate excise tax base using the single sales factor formula for manufacturing corporations, instead of the three factor formula.
Ford & Harrison LLP
In January of this year, the U.S. Tax Court decided Bobrow v. Commissioner, T.C. Memo. 2014-21 ("Bobrow"),in which it decided that the once-per-year limit on IRA rollovers that is imposed by the Internal Revenue Code...
In September, the Tax Court issued its opinion in Cavallaro v. Commissioner, T.C. Memo 2014-189, holding that a merger of two family-owned businesses resulted in a $29.6 million gift from Mr. and Mrs. Cavallaro to their three sons.
On November 13, 2014, Hong Kong announced that it had signed a Model 2 FATCA IGA. Under the agreement Hong Kong financial institutions will enter into separate FFI agreements with the IRS and will report information on U.S. account holders directly to the IRS.
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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.
McDermott Will & Emery
FATCA went into effect on July 1, 2014, after numerous delays and multiple rounds of administrative guidance.
McGuireWoods LLP
On January 27, 2014, the Internal Revenue Service published Revenue Procedure 2014-18.
Fisher & Phillips LLP
The IRS handed health care flexible spending account participants an early Christmas present on Halloween when it modified cafeteria plan "use-it-or-lose-it" rules.
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.
Proskauer Rose LLP
On October 31, 2013, the Internal Revenue Service (IRS) released Notice 2013-71 (Notice), which modifies the "use or lose" rule for health flexible spending accounts (health FSAs) to allow a $500 annual carryover of unused contributions, provided that cafeteria the plan offering the health FSA does not incorporate the "grace period" rule.
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.
Duane Morris LLP
On June 18, 2014, the Internal Revenue Service (IRS) announced major changes in its offshore voluntary compliance programs.
Holland & Knight
The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the OVDP.
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.
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