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Searching Content indexed under Corporate/Commercial Law by Grant Thornton LLP ordered by Published Date Descending.
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1
Transfers Of Securities Result In No Loss, IRS Says In Technical Advice
The IRS concluded in a technical advice memorandum (TAM 201737011), released on Sept. 15, 2017, that transfers of stock did not result in losses recognized by the respective taxpayers.
United States
5 Oct 2017
2
Minnesota Tax Court Holds Definition Of 然esident Trust' Unconstitutional As Applied To Inter Vivos Trusts
On May 31, 2017, the Minnesota Tax Court overturned as unconstitutional the taxation of certain trusts as Minnesota "resident trusts" and held that application of the statutory definition of "resident trust"...
United States
8 Sep 2017
3
Michigan Supreme Court Clarifies Eligibility Requirements For Charitable Institution Property Tax Exemption
On June 28, 2017, the Michigan Supreme Court unanimously held that a charitable institution that imposes certain restrictions or conditions on its beneficiaries may still qualify for a property tax exemption...
United States
8 Sep 2017
4
There's A Difference Between Restricted Stock And Restricted Stock Units
Restricted stock and restricted stock units (RSUs) -- they're the same thing, right? This is one of the most common misconceptions about these equity vehicles.
United States
30 Aug 2017
5
Minnesota Tax Court Holds Definition Of 然esident Trust' Unconstitutional As Applied To Inter Vivos Trusts
On May 31, 2017, the Minnesota Tax Court overturned as unconstitutional the taxation of certain trusts as Minnesota "resident trusts" and held that application of the statutory definition of "resident trust"...
United States
10 Aug 2017
6
Tax Court Addresses Limited Partner Exception In LLC Context
Tax Court has held in Castigliola v. Commissioner that three lawyers who were member-managers of a PLLC classified as a partnership for U.S. federal income tax purposes were not entitled to exclude a portion of their partnership income...
United States
26 Jun 2017
7
IRS Applies New Qualified Liability Rule In Letter Ruling
In a recently released private letter ruling (PLR 201714028), the IRS Office of Chief Counsel determined that liabilities transferred by a taxpayer to a partnership constituted qualified liabilities...
United States
23 Jun 2017
8
Taxpayer Ineligible To Use The Completed Contract Method, Court Rules
In Basic Engineering v. Commissioner, T.C Memo 2017-26 (Feb. 1, 2017), the Tax Court ruled that an engineering company was ineligible to use the completed contract method and was liable for an accuracy-related penalty.
United States
21 Apr 2017
9
Appeals Court Limits Application Of Substance-Over-Form Doctrine
The Sixth Circuit reversed the Tax Court and held that the IRS could not apply the substance-over-form doctrine to recharacterize commission payments made to a domestic international sales corporation (DISC) that was owned by a Roth IRA.
United States
27 Mar 2017
10
Final Regulations Retroactively Affect Nonrecognition On Outbound Transfers Of Foreign Goodwill
The Treasury Department and the IRS recently issued final regulations relating to certain transfers of property by U.S. persons to foreign corporations (T.D. 9803).
United States
26 Jan 2017
11
IRS Issues Final Regulations On Information Reporting And Record Maintenance For Certain Disregarded Entities
The Department of the Treasury and the IRS recently released final regulations (T.D. 9796) that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation...
United States
26 Jan 2017
12
Tax Court Holds That Co-Borrowing Does Not Generate S Corp Debt Basis
The U.S. Tax Court held that a shareholder of several S corporations did not receive any basis in indebtedness to the S corporations merely from signing as a co-borrower on loans....
United States
26 Jan 2017
13
Final Regulations Under Section 956 Adopt An Aggregate Approach To CFCs Transacting With Foreign Partnerships
New, final regulations under Section 956 (T.D. 9792), addressing the treatment of U.S. property held by a controlled foreign corporation in connection with certain transactions involving partnerships.
United States
21 Dec 2016
14
Notice Modifies The Application Of Section 367 To Certain Triangular Reorganizations And Inbound Transactions
The IRS on Dec. 2 issued Notice 2016-73 announcing that the government intends to issue regulations under Section 367 modifying the rules relating to the treatment of property used to acquire parent stock...
United States
21 Dec 2016
15
Disrupting The Disruptors
Renowned as the disruptors of other industries, information technology (IT) companies are now subject to a dizzying pace of change, driven by the global pervasiveness of their own technologies.
United States
14 Nov 2016
16
California FTB Issues Guidance On Effect Of Economic Nexus On Water's-Edge Combined Reporting Groups
The California Franchise Tax Board (FTB) has recently issued guidance to clarify the rules for water's-edge filers with foreign affiliates...
United States
20 Oct 2016
17
Texas Letter Ruling Denies Capital Asset Or Investment Treatment For Goodwill And Government Permits And Licensing
On July 22, 2016, the Texas Comptroller of Public Accounts issued a letter ruling addressing the proper apportionment of gross receipts from the sale of substantially all of the assets of a company located in Texas to an entity incorporated in Delaware.
United States
20 Oct 2016
18
Treasury Issues Proposed Regulations Addressing Two Aspects Of RIC Qualification
The Treasury Department and the IRS recently issued proposed regulations (REG-123600-16) that provide guidance on the requirements a corporation must satisfy to qualify as a regulated investment company.
United States
18 Oct 2016
19
Court Holds Deposit From Terminated Sale Contract Isn't Capital Gain
The Tax Court has held in CRI-Leslie, LLC v. Commissioner (147 T.C. No. 8) that a partnership recognized ordinary income from its gain from a terminated sale contract.
United States
12 Oct 2016
20
Texas Comptroller Issues Franchise Tax Guidance Regarding
For purposes of the Texas franchise tax, the Texas Comptroller of Public Accounts recently issued an internal memo from the Tax Policy Division to the Audit Division outlining the treatment of VFIs received by retailers...
United States
11 Oct 2016
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