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  • Article

    Inclusion of Business Income Dividends in The Sales Factor post-CERIDIAN and FARMER BROS.

    On December 4, 2003, the California Franchise Tax Board (FTB) issued Legal Ruling 2003-3 to address the issue of when income-producing activity exists with respect to a business income dividend so that the dividend is includible in the payee’s sales factor.
    United StatesTax
    Pillsbury Winthrop Shaw Pittman
    Pillsbury Winthrop Shaw Pittman
  • Article

    IRS Issues Regulations On Section 7874 Inversion Transactions

    The IRS has issued temporary and proposed regulations (T.D. 9592 and REG-107889-12) adopting a bright line test for determining whether a foreign corporation satisfies the substantial business activities test of Section 7874(a)(2)(B)(iii) to avoid treatment as an inverted corporation.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Scrutinizes Payroll Practices, Challenges for Companies

    The IRS estimates that companies underpay approximately $14 billion annually by misclassifying employees as independent contractors.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Non-Corporate Taxation: Individuals & Partnerships Face Highs & Lows Under The T.C.J.A.

    The Tax Cuts and Jobs Act ("T.C.J.A.") brought many changes for non-corporate taxation, changing tax rates and repealing many popular deductions.
    United StatesTax
    Ruchelman PLLC
    Ruchelman PLLC
  • Article

    President Trump's Tax Plan

    In rounding out his first 100 days in office, President Trump released an overview of his proposed tax plan
    United StatesTax
    Butler Snow LLP
    Butler Snow LLP
  • Article

    Recent Developments in the Tax Shelter Area

    The ongoing enforcement effort against abusive tax shelters has taken several turns in the past few months. Taxpayers and practitioners who have shelter issues need to be aware of a number of recent developments
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Sixth Circuit Defines ‘Corporation' For Purposes Of Overpayment Interest

    The Sixth Circuit held that a nonprofit entity incorporated under state law falls within the definition of a ‘corporation' for purposes of determining the interest rate applicable to tax refunds.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    August 16 Corporate News Update: U.S. Expands Scrutiny Of All-Cash Real Estate Purchases, CFTC Proposes Broader Registration Exemptions For Non-U.S. Intermediaries And IRS Allows Early Application Of New Partnership Audit Rules

    This week's Corporate news roundup includes information regarding the widening geographic net cast by FinCEN's review of all-cash real estate purchases in NYC, Florida, California and Texas.
    United StatesCorporate/Commercial Law
    Withers LLP
    Withers LLP
  • Article

    Exclusion For Qualified Small Business Stock

    The Protecting Americans from Tax Hikes Act, passed in December 2015, extended an often overlooked provision of the tax code with the potential to provide significant savings...
    United StatesCorporate/Commercial Law
    Foley & Lardner LLP
    Foley & Lardner LLP
  • Article

    IRS Narrows Definition Of "Liquid Hydrocarbons Derived from Biomass"

    Notice 2007-97, released by the IRS on November 13, 2007, originally as Notice 2007-92, made a narrow retroactive change (back to October 1, 2006) to the definition of "liquid hydrocarbons derived from biomass" for purposes of the alternative fuel credit and alternative fuel mixture credit, to clarify the definition to exclude oil, natural gas, coal, or any product derived from these three products.
    United StatesEnergy and Natural Resources
    Mayer Brown
    Mayer Brown
  • Article

    IRS Imposes Additional Penalty On Public Companies That Fail To Disclose Tax Penalties In SEC Reports

    A public company that files periodic reports with the Securities and Exchange Commission (“SEC”) under Section 13 or 15(d) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), is required to disclose certain tax penalties in its Annual Report on Form 10-K.
    United StatesFinance and Banking
    Blank Rome LLP
    Blank Rome LLP
  • Article

    Which Medical Devices Are Taxable? Agencies Have Conflicting Interpretations

    Amid conflicting agency regulations, contract manufacturers of device components and finished devices may be subject to the new medical device excise tax.
    United StatesFood, Drugs, Healthcare, Life Sciences
    McGuireWoods LLP
    McGuireWoods LLP
  • Article

    California Court Of Appeal Confirms Quasi-Judical Immunity For Receivers

    A new court decision confirms that receivers cannot be sued for decisions made in the exercise of their judgment...
    United StatesLitigation, Mediation & Arbitration
    Jeffer Mangels & Mitchell LLP
    Jeffer Mangels & Mitchell LLP
  • Article

    The Dreaded Capital Stock/Franchise Tax Remains Alive On "Life Support"

    For the past decade, the PA Department of Revenue has been committed to abolishing the PA Capital Stock/Franchise Tax, which is a tax on the value of a corporation’s capital stock.
    United StatesReal Estate and Construction
    Fox Rothschild LLP
    Fox Rothschild LLP
  • Article

    Advisory Committee On Tax Exempt And Government Entities Makes Recommendations On Reporting Of Unrelated Business Taxable Income

    The Advisory Committee on Tax Exempt and Government Entities made several recommendations on issues relating to unrelated business taxable income.
    United StatesTax
    Proskauer Rose LLP
    Proskauer Rose LLP
  • Article

    Alabama May Have Dodged A Bullet In 4-R Act Tax Discrimination Case

    The U.S. District Court for the Northern District of Alabama issued an important ruling last Friday in the ongoing battle between the railroad companies and the State of Alabama regarding whether the differing taxes and exemptions applied to diesel fuel purchased by railroads versus interstate trucking companies and interstate water carriers violates the Railroad Revitalization and Regulatory Reform Act ("4-R Act"), 49 U.S.C. §11501.
    United StatesTax
    Bradley Arant Boult Cummings LLP
    Bradley Arant Boult Cummings LLP
  • Article

    California Legislature Passes Bill Applying Retroactive LLC Fee Formula

    On March 24, 2006, we posted a client alert detailing the California Franchise Tax Board’s published procedures for taxpayers wishing to file protective claims in response to "Northwest Energetic Services, LLC v. California Franchise Tax Board".
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Article

    COBRA and Domestic Partner Group Health Plan Coverage

    We frequently review health plans maintained for employees by their employers. Some of these group health plans provide domestic partner coverage, not only for an employee's unmarried partner of the same or opposite sex, but also for the dependents of these partners. This scenario presents some interesting results under the continuation coverage rules of the federal law called the Consolidated Omnibus Budget Reconciliation Act of 1985, or "COBRA."
    United StatesTax
    Rothgerber Johnson & Lyons LLP
    Rothgerber Johnson & Lyons LLP
  • Article

    COMMONWEALTHCourt Rules that Pennsylvania Municipalities May Not Impose Business Privilege Tax on Rental Real Estate Business

    In a decision with wide-ranging implications and potential refund opportunities, Pennsylvania’s Commonwealth Court ruled on September 19th that Pennsylvania municipalities (other than Philadelphia) may not impose their business privilege tax ("BPT") on a rental real estate business.
    United StatesTax
    Blank Rome LLP
    Blank Rome LLP
  • Article

    Development Of Practice On Treating Of Facilities As Immovable Property For The Purpose Of Imposing Corporate Property Tax

    On 12 July 2016 the Commercial Court of Moscow rendered a decision in case No. А40-98958/16-108-827.
    United StatesTax
    Dentons
    Dentons
  • Showing 881–900 of 3726 results

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