Searching Content indexed under Tax by Carlton Fields ordered by Published Date Descending.
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Intentional Accidents: California Supreme Court Announces That General Commercial Liability Policies Apply To Negligent Hiring, Training, And Supervising Claims For Failing To Prevent Intentional Torts
In a recent decision, the U.S. Court of Appeals for the Ninth Circuit observed that under California law, there was an unresolved question as to whether a commercial general liability ...
United States
12 Dec 2018
Recent Change To Hardship Distributions Can Increase Employer Liabilities
This alert should interest sponsors of retirement plans subject to IRC sections 401(k), 403(b), or 457(b) that authorize hardship distributions ...
United States
12 Dec 2018
Real Property, Financial Services & Title Insurance Update
Imputation of Implied Actual Notice: the fact that an unrelated purchaser of property was aware that seller was being sued on an unsecured indebtedness did not create a legal duty...
United States
15 Nov 2018
Hillsborough County Voters Pass Transportation Surtax - What Happens Next?
More than 57 percent of Hillsborough County voters approved the imposition of a 1 percent sales tax designed to improve the County's transportation infrastructure and transit service.
United States
14 Nov 2018
Suitability Working Group Stirs Ingredients For Suitability Model Potion
On October 22 and 23, the NAIC Annuity Suitability (A) Working Group (Suitability WG) held an interim meeting to review comments received on the Suitability in Annuity Transactions Model Regulation ...
United States
30 Oct 2018
IRS Allows Employer ‘Matching Contribution' Based On Student Loan Repayments
In IRS Private Letter Ruling 201833012, the employer made matching contributions to any employees who salary deferred at least 2 percent.
United States
28 Sep 2018
Tax Court Rejects Captive Insurance Company Status Under 501(C)(15)
Petitioner, a captive insurer domiciled in Anguilla, applied to be a tax-exempt small insurance company under IRC section 501(c)(15), and filed returns on this basis, making an election under IRC section 953(d).
United States
22 Aug 2018
New Jersey Tax Court Finds That Companies For Which New Jersey Is The Home State Must Pay Taxes On All Premiums Paid To Captive Insurers For U.S. Based Risks.
A tax court judge in New Jersey has handed Johnson & Johnson (J&J), and likely other New Jersey-based businesses that operate captive insurers, a significant loss in an opinion interpreting...
United States
15 Aug 2018
Cost-Sharing Regulations Revived By Ninth Circuit
The Ninth Circuit Court of Appeals reversed the Tax Court in Altera Corp. in the latest chapter of the dispute over the validity of cost-sharing regulations.
United States
6 Aug 2018
U.S. Tax Court Finds Captive Insurer Is Not An "Insurance Company" Under The Internal Revenue Code
In this case, Reserve Mechanical Corp., a captive insurer incorporated under the laws of Anguilla, sued the Commissioner of Internal Revenue in the U.S. Tax Court regarding the Commissioner's findings of $477,261
United States
31 Jul 2018
Retirement Plans Can Solve The Million-Dollar Problem For Entities At Risk Of Excise Taxes On Compensation
All entities, including governmental entities, are now potentially liable for penalties[1] due to overpaying employees.
United States
4 Jul 2018
Excise Tax Problems? Retirement Compensation May Help
All entities, including governmental entities, are now potentially liable for overpaying higher-ranking employees.
United States
3 Jul 2018
The Hidden Cost Of Settling A Qui Tam Claim
Now more than ever, companies must carefully consider the tax treatment of these payments when negotiating False Claims Act settlements with the DOJ.
United States
22 Jun 2018
Get Ready: IRS To End OVDP
Recently, I discussed the impact of so-called "soft letters" sent by the IRS to various groups of taxpayers with offshore asset disclosure compliance issues (see this generic example of an IRS soft letter).
United States
24 Apr 2018
Tax Reform: Insurance Company Provisions
Recent tax legislation, informally known as the Tax Cuts and Jobs Act (the "Act") contains several changes that affect the insurance industry.
United States
18 Apr 2018
New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status
The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters
United States
9 Apr 2018
IRS And Cryptocurrencies: Coinbase Is Just The Beginning
Last year was a breakout year for cryptocurrencies. At its height, bitcoin's value increased by more than 20 times from the start of the 2017 ...
United States
26 Feb 2018
Virtual Currency Tax Consequences
A growing number of startups are offering virtual currencies to investors through initial coin offerings (ICOs) as a way to raise capital, often with little or no awareness of the tax consequences of their actions.
United States
23 Feb 2018
Tax Incentive For Paid Family Medical Leave May Alleviate FMLA Benefit Complications
Not only does the Tax Cuts and Jobs Act contain a tax incentive to promote the offering of paid family medical leave (FML), but it creates a lower-cost way to eliminate common complications ...
United States
20 Feb 2018
A Day Of Reckoning For Recalcitrant Taxpayers?
Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009
United States
26 Jan 2018
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