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  • Article

    IRS Releases Guidance And Due Dates For 2013 Pharmaceutical Industry Fee

    The IRS has issued guidance (Notice 2012-74) providing the due dates for the various forms and procedures for the 2013 pharmaceutical industry fee year.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Releases Sample Language For Section 83(B) Elections

    The IRS has provided sample language (Rev. Proc. 2012-29) that may be used (but is not required to be used) for making an election under Section 83(b).
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
Article

IRS Revokes Letter Ruling On Valuation Of Acquired Power Purchase Agreements

The IRS has issued a private letter ruling (PLR 201249013) revoking a ruling issued earlier this year related to the cost of facility-specific power purchase agreements (PPAs).
United StatesTax
Grant Thornton LLP
Grant Thornton LLP
  • Article

    IRS Rules On Capital Loss Carryover Rules For Regulated Investment Companies

    The IRS has ruled in Rev. Rul. 2012-29 that the loss carryover rules in amended Section 1212(a) apply beginning with any net capital loss recognized in the period that determines a regulated investment company’s (RIC’s) required distribution for calendar year 2011.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS To Reject Checks With Amounts Greater Than $100 Million

    The IRS announced Sept. 7 that beginning in 2016, it would no longer accept checks in an amount of $100 million or more, citing an inability to process checks of that size.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Will Not Acquiesce On Retroactive Rulings Decision

    The IRS has released an action on decision formally rejecting a 1966 Court of Claims opinion in "IBM v. U.S."
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    License Fees Are Not Royalties For Section 165(g)(3) Purposes

    The IRS has ruled in a heavily redacted private letter ruling (PLR 201325007) that licensed fees were not considered royalties for purposes of its worthless stock deduction under Section 165(g)(3).
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Massachusetts Tax Regulation Changes On The Way—Department Of Revenue Lays Out Plans For Amended And New Regulations For 2014

    The Massachusetts Department of Revenue has released its plans for drafting new and amended state tax regulations for 2014.
    United StatesTax
    Reed Smith
    Reed Smith
  • Article

    Memorandum Outlines Power Of Attorney Authorization For TEFRA Partnerships

    GLAM 2015-004 states that a general partner of a partnership, or a member-manager of an LLC, may sign a POA for purposes of the TEFRA examination or for other purposes of the partnership.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Michigan Court Of Appeals Ruling Allows Compact Election For Lorillard

    We argued the case in the Michigan Court of Appeals on September 4, 2014.
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Article

    Mid-Year Changes To Safe-Harbor Plans

    On November 14, 2013, the Internal Revenue Service issued final regulations modifying some of the conditions for making mid-year changes to employer matching or nonelective contributions under plans that utilize the nondiscrimination safe harbors under sections 401(k) and/or 401(m) of the Internal Revenue Code.
    United StatesTax
    Ford Harrison LLP
    Ford Harrison LLP
  • Article

    New Bill Would Bring Opportunity-Zone-Style Tax Breaks To U.S. Shipbuilding

    Representative Mike Kelly has introduced legislation to establish up to 100 maritime prosperity zones across coastal areas, major rivers, and the Great Lakes, offering targeted tax incentives to maritime supply chain companies, workforce training programs, and advanced manufacturing operations. The proposal aligns with the Trump administration's broader initiative to revitalize the domestic maritime industry by layering new maritime designations onto the existing Qualified Opportunity Zones framework.
    United StatesTax
    Liskow
    Liskow
  • Article

    New Jersey Tax Court Issues Bench Ruling That Dual Nexus Standards Are Inappropriate In Applying Throwout

    In response to numerous inquiries for copies of our Transcript of ruling and argument following our August 22, 2013 alert, click here for a copy of the Transcript of the New Jersey Tax Court’s bench ruling that the Division of Taxation may not apply dual nexus standards for Throwout purposes.
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Article

    New Jersey’s Corporation Business Tax Held Applicable To Foreign Corporations With A Single Employee Telecommuting From New Jersey

    In a case of first impression, the Appellate Division held a foreign corporation that regularly and consistently permits one of its employees to telecommute from a New Jersey residence is doing business in New Jersey, is subject to the New Jersey Corporation Business Tax Act, and must file New Jersey Corporation Business Tax returns.
    United StatesTax
    Ogletree, Deakins, Nash, Smoak & Stewart
    Ogletree, Deakins, Nash, Smoak & Stewart
  • Article

    New Regulations Affect U.S. Shareholders Of CFCs Transacting With Foreign Partnerships

    Proposed regulations released concurrently with the temporary regulations provide rules regarding the treatment as U.S. property of property held by a CFC in connection with certain transactions involving partnerships.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    New York State Tax Department Releases Draft Combined Reporting Regulations Under Corporate Tax Reform

    The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise tax regulations.
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Article

    NYC Finance Department Issues Audit Guidance To Financial Services Firms Engaged In Repo And Securities Lending Activities

    On March 31, 2008, the New York City Department of Finance issued a Statement of Audit Procedure with respect to the tax treatment of repurchase agreements and securities lending transactions for financial service firms regularly engaged in such activities for purposes of the general corporation tax and unrelated business tax.
    United StatesTax
    Proskauer Rose LLP
    Proskauer Rose LLP
  • Article

    "Pass-Through Deduction Primer"

    There were several changes to the income tax—including the reduction in the top corporate tax rate to 21 percent, the reduction in individual income tax rates, including a new top marginal ...
    United StatesTax
    Stroock & Stroock & Lavan LLP
    Stroock & Stroock & Lavan LLP
  • Article

    "Passthrough Partner: Partnership Options, Warrants, Convertible Debt and Convertible Equity – Not for the Start-Up or Unsophisticated" by J. Leigh Griffith and Shane P. Morris, Taxes – The Tax Magazine

    Article from Waller Law.
    United StatesTax
    Waller Lansden Dortch & Davis
    Waller Lansden Dortch & Davis
  • Article

    Recent NY State Decision: Corporation’s License Fee To Be Recomputed Based On The Rate Applicable To Par Value Stock

    The New York State Tax Appeals Tribunal reversed the determination of an Administrative Law Judge and held that the issued capital stock of frog design, inc., a California corporation, had a par value of $1 per share.
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Showing 241–260 of 3726 results

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