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  • Article

    Permanent Establishments Series #4: Allocation Of Profits If A PE Is Considered Present – New York Office Snippet

    When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...
    United StatesTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Possible Impact On Alabama Taxpayers: Michigan Supreme Court Rules That IBM Entitled To Use Multistate Tax Compact Election

    The Michigan Supreme Court ruled that IBM was entitled to apportion its business income using the Multistate Tax Compact’s Article III election.
    United StatesTax
Bradley Arant Boult Cummings LLP
Bradley Arant Boult Cummings LLP
  • Article

    Reed Smith State Tax Team Obtains Attorney Fee Award For Client: Court Orders Franchise Tax Board To Pay $1.2 Million

    After a contentious 12-year battle with the California Franchise Tax Board, culminating with a lopsided victory at trial, Reed Smith has now achieved total vindication for Orange County real estate entrepreneur Ron Lane in Daniel V, Inc. v. Franchise Tax Board.
    United StatesTax
    Reed Smith
    Reed Smith
  • Article

    Senate Hearing On Profit Shifting

    The Senate Permanent Subcommittee on Investigations held another hearing on multinational corporations that shift their profits out of the U.S.
    United StatesTax
    Jones Day
    Jones Day
  • Article

    Small Business Jobs Act Offers Tax Incentives

    In addition to expanding lending to small businesses, the Small Business Jobs Act ("SBJA"), effective September 27, 2010, also includes several tax provisions which aim to encourage investment, promote entrepreneurship and provide small business relief.
    United StatesTax
    Dinsmore & Shohl LLP
    Dinsmore & Shohl LLP
  • Article

    Tax Day for Tax-Exempt Organizations (But Not Yet)

    The due date for filing the required information return for a tax-exempt organization is just around the corner. Returns for the 2010 calendar taxable year are due May 15, 2011 unless an organization files a request for extension.
    United StatesTax
    McGuireWoods LLP
    McGuireWoods LLP
  • Article

    Treasury And IRS Finalize Reporting Rules For Section 1035 Exchanges And Transfers Of Life Insurance Contracts

    The Department of the Treasury and the Internal Revenue Service have issued final regulations addressing reporting obligations for certain tax-free exchanges of life insurance contracts under Internal Revenue Code...
    United StatesTax
    Liskow
    Liskow
  • Article

    Proposed Regulations Would Block Some Spinoffs

    Proposed regulations issued on July 14, 2016 generally would prevent tax-free spinoffs involving companies with less than 5% active business assets and spinoffs...
    United StatesCorporate/Commercial Law
    Hogan Lovells Cadwalader
    Hogan Lovells Cadwalader
  • Article

    New P3 Infrastructure Opportunities On The Way For Government Contractors?

    In his recent State of the Union address, President Obama proposed expanding a program that encourages state and local governments to fund infrastructure projects through public-private partnerships (or P3s).
    United StatesGovernment, Public Sector
    Fox Rothschild LLP
    Fox Rothschild LLP
  • Article

    Maryland Extends Corporate Information Reporting Requirement Due Date And Softens Penalty Provisions

    In a late-breaking stunning victory for corporate taxpayers, at a public hearing yesterday Maryland General Assembly’s Joint Committee on Administrative, Executive, and Legislative Review (“AELR”) extended the due date for Maryland’s new corporate income tax information reporting requirements for an additional 45 days.
    United StatesReal Estate and Construction
    Sutherland Asbill & Brennan LLP
    Sutherland Asbill & Brennan LLP
  • Article

    PEPping Up The Economy And Employers

    On October 26, Governor Tom Corbett (R-PA) signed into law the Promoting Employment Across Pennsylvania Act (PEP) (House Bill 2626).
    United StatesStrategy
    Drinker Biddle & Reath LLP
    Drinker Biddle & Reath LLP
  • Article

    The Trump Scorecard – One Year Later

    In our inaugural Wealth Management newsletter in February, 2017, we analyzed the President's campaign platform and made predictions about the President's legislative agenda.
    United StatesStrategy
    Womble Bond Dickinson
    Womble Bond Dickinson
  • Article

    As Minnesota Moves Toward GILTI Taxation, New Jersey May Be Moving Away From It

    We previously reported that the Minnesota Legislature was considering imposing mandatory worldwide combined reporting through an omnibus tax bill. Subsequent to our report and in the face of numerous...
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Congress Approves Tax Reform Bill Impacting Equity Compensation

    The Tax Cuts and Jobs Act was passed by both chambers of Congress on Wednesday, December 20, 2017, and will be sent to the President's desk for final signature.
    United StatesTax
    Fenwick
    Fenwick
  • Article

    Developers Take Advantage Of Low Income Housing Development Tax Credits, But Recent Third Circuit Decision Stirs Controversy

    Developers of multi-family apartment complexes geared to low- to moderate-income tenants are increasingly taking advantage of federal low-income housing tax credits (LIHTC) and, where available, their state counterparts, to finance such developments.
    United StatesTax
    Thompson Coburn LLP
    Thompson Coburn LLP
  • Article

    Economists Pledge To Trim Cost Of Trump's Tax Reform Plan

    Two economists said last week that the presidential campaign of Republican nominee Donald Trump has asked them to revise Trump's tax plan to slash the cost.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Announces Activities It Won’t Accept For Section 199 Deduction

    The IRS Large Business and International (LB&I) Division has announced that it will not treat certain activities as manufacturing, producing, growing or extracting (MPGE)...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Grants Extension For Electing Safe Harbor For Success-Based Transaction Fees

    The IRS has released a private letter ruling extending the time for a corporation to elect safe harbor treatment under Rev. Proc. 2011-29 for a success-based transaction fee.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Publishes Proposed Regulations For Hedge Fund Reinsurance Arrangements

    Once effective, the proposed rules are likely to cover both existing and future entities
    United StatesTax
    BakerHostetler
    BakerHostetler
  • Article

    IRS Restructuring Large Business And International Division

    While the IRS has not released official guidance on the changes, several senior LB&I officials have offered remarks publicly on the restructuring.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Showing 461–480 of 3726 results

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