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  • Article

    New Proposed Regulations Under Section 871(m) Adopt A Single Factor Test But Delay Effective Date Until 2016

    On December 4, 2013, the Treasury Department and the Internal Revenue Service released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal withholding tax on certain equity-linked payments.
    United StatesTax
    A&O Shearman
    A&O Shearman
  • Article

    New Rules For Non-Domiciled Individuals Announced

    The 2011 Budget has announced that non-domiciled individuals who want to use the remittance basis of taxation will face a flat rate charge of £50,000 when they have been UK resident for 12 or more tax years.
    United StatesTax
    McGuireWoods LLP
    McGuireWoods LLP
  • Article

    Nine Key Tax Issues For Startup Founders To Consider

    Grady Bolding, a partner in Orrick's Tax team in San Francisco, recently co-authored an article with Orrick alum Richard Harrochs, now a Managing Director and Global Head of M&A...
    United StatesTax
    Orrick
    Orrick
  • Article

    Nonprofit Executive Compensation: Avoiding The Treacherous Tax And Governance Pitfalls

    Few issues facing nonprofit organizations these days are as prominent as executive compensation.
    United StatesTax
    Venable LLP
    Venable LLP
  • Article

    Ofer Lion And Dustin Lauermann Authored An Article In TaxStringer

    Ofer Lion and Dustin Lauermann authored a December 1 article in TaxStringer, "Understanding Your Tax-Exempt Investors." The Seyfarth attorneys said that as tax-exempt organizations...
    United StatesTax
    Seyfarth Shaw LLP
    Seyfarth Shaw LLP
  • Article

    Oklahoma Supreme Court Allows Individual To Take Capital Gain Deduction For Sale Of S Corporations' Goodwill

    On June 27, 2017, in a unanimous decision, the Oklahoma Supreme Court reversed the Oklahoma Tax Commission and held that an individual taxpayer could take a capital gain deduction for the proceeds...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Oklahoma Supreme Court Allows Individual To Take Capital Gain Deduction For Sale Of S Corporations' Goodwill

    On June 27, 2017, in a unanimous decision, the Oklahoma Supreme Court reversed the Oklahoma Tax Commission and held that an individual taxpayer could take a capital gain deduction for the proceeds that he received...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Out-Of-State Subsidiary Holding Company Cannot Be Forcibly Included In A Colorado Combined Return

    A Denver District Court judge has held that the Colorado Department of Revenue cannot forcibly combine a corporation's subsidiary, a holding company that derived its income solely from investments...
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Article

    PA Court Precludes Appraisal By Non-Testifying Expert

    A Pennsylvania state appellate court recently held that a taxing authority could not present an appraisal prepared by a non-testifying expert for the taxpayer.
    United StatesTax
    Fox Rothschild LLP
    Fox Rothschild LLP
  • Article

    "Paid Overpayments, Settlements Could Be Tax Deductible," Leigh Griffith Quoted In Medical Practice Compliance Alert

    Article from Waller's Media Mentions.
    United StatesTax
    Waller Lansden Dortch & Davis
    Waller Lansden Dortch & Davis
  • Article

    Partnership Terminations: When Does Something Become Nothing

    In a recent Tax Notes Special Report article, tax associate Bob Kane explores whether case law has established an asset threshold at which liquidating partnerships either terminate or continue under section 708.
    United StatesTax
    Ropes & Gray LLP
    Ropes & Gray LLP
  • Article

    Pass-Through Entities Update: Will The States Conform To Federal Classification Of Series LLCs Once The Proposed Regulations Are Finalized?

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

    Passthrough Partner - Code Sec. 336(e) Corporation To Partnership, Tax Alchemy? Important New Tool For Stock Acquisitions—27 Years In The Making

    Section 336(e) of the Internal Revenue Code of 1986, as effectuated by the final regulations promulgated in May 2013, is obviously an important corporate tax provision.
    United StatesTax
    Waller Lansden Dortch & Davis
    Waller Lansden Dortch & Davis
  • Article

    "Passthrough Partner: Partners And W-2 Employee Status," By J. Leigh Griffith, Taxes - The Tax Magazine

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

    Pending New Regulations Will Eliminate Certain Valuation Discounts For Gift And Estate Tax Purposes

    A few days ago, IRS personnel advised that they are "getting close" to issuing gift and estate tax regulations under Section 2704 of the Internal Revenue Code...
    United StatesTax
    Milbank
    Milbank
  • Article

    Philadelphia Property Tax Reduction Opportunities

    Property taxes are often one of a company's largest recurring operating expenses.
    United StatesTax
    Duff and Phelps
    Duff and Phelps
  • Video

    Planning For Excise Tax And Base Erosion Minimum Tax (Video)

    Planning For Excise Tax And Base Erosion Minimum Tax (Video)
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Video

    Planning For Excise Tax And Base Erosion Minimum Tax (Video)

    Planning For Excise Tax And Base Erosion Minimum Tax
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Podcast: Cum-Ex Dividend Trade Investigations

    In this Ropes & Gray podcast, Alec Oveis, an associate in the tax and benefits group is joined by Kat Gregor
    United StatesTax
    Ropes & Gray LLP
    Ropes & Gray LLP
  • Article

    Podcast: Texas v. United States Of America

    This case deals with the constitutionality of the Individual Mandate in the Patient Protection and Affordable Care Act.
    United StatesTax
    Ropes & Gray LLP
    Ropes & Gray LLP

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