Mondaq USA: Tax
Withers LLP
Works of art, like other tangible property, may be subject to state sales or use tax unless an exemption applies.
Grant Thornton LLP
In Petersen v. Commissioner, 148 T.C. No. 22 (June 13, 2017), the Tax Court addressed the application of Section 267(a)(2) to an S corporation that maintains an employee stock ownership plan (ESOP).
Grant Thornton LLP
The commissioners of the IRS Large Business and International Division and the Small Business/Self-Employed Division, who together oversee all business taxpayers...
Grant Thornton LLP
Republicans are struggling to move forward on a budget resolution that would allow them to create reconciliation instructions to ease the passage of tax reform.
Dickinson Wright PLLC
The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative.
Dechert
Well, we've had the big reveal and the administration's new tax plan is out. This plan, announced with a great deal of fanfare, feels more like a campaign promise than an actual executable plan.
Duane Morris LLP
Overriding Governor Bruce Rauner's veto, the new Illinois budget bill passed on July 6, 2017, imposes some major income tax increases for both corporate and non-corporate businesses,...
Reed Smith
The Massachusetts Appellate Tax Board ("ATB") has issued an order denying three sales tax refund claims involving multiple points of use ("MPU") sourcing. In each case, vendors had filed refund claims...
Day Pitney LLP
In a significant setback for the IRS, the U.S. Tax Court held in a July 13 opinion that a foreign corporation did not have to pay U.S. tax on gain realized from the redemption of a partnership interest.
Cadwalader, Wickersham & Taft LLP
The United States Senate Committee on Finance (the "Committee") will hold hearings on July 18, 2017 to discuss options for overhauling the tax code and to consider the nomination of...
Lowndes, Drosdick, Doster, Kantor & Reed, P.A.
Last summer, we discussed the IRS's issuance of new Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts made to family members.
McDermott Will & Emery
Can a seller have nexus with a state – so as to be obligated to collect and remit that state's sales and use taxes – only in connection with certain sales that seller makes into that state?
Morrison & Foerster LLP
On July 11, 2017, the Indiana Tax Court released a decision in E.I. DuPont de Nemours and Company v. Indiana Department of State Revenue.
Akin Gump Strauss Hauer & Feld LLP
Recent IRS guidance requires that non-U.S. investment funds currently relying on an FFI agreement for their FATCA compliance must renew such agreement on the IRS website by July 31, 2017...
Thompson Coburn LLP
I was recently honored to serve as a guest columnist in the June 2017 "Shop Talk" column in WG&L's Journal of Taxation.
Grant Thornton LLP
The Treasury Department on July 7 issued Notice 2017-38 which identifies eight regulations — including those issued under Section 385 — that could be subject to some reform, including modification...
McDermott Will & Emery
A legal challenge to Cook County Illinois Sweetened Beverage Tax (Tax) heads back to circuit court today for a hearing on the plaintiffs' motion for preliminary injunction.
Lowndes, Drosdick, Doster, Kantor & Reed, P.A.
Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden...
McDermott Will & Emery
Our June 2017 blog posts are available on insidesalt.com, or read each article by clicking on the titles below.
Duff and Phelps
In this edition: the OECD releases discussion draft on hard-to-value intangibles, Australia issues risk framework for evaluating intercompany loans, recent transfer pricing developments in India, ...
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Akin Gump Strauss Hauer & Feld LLP
Despite the headlines coming out of Washington, Congress continues to move forward in regular fashion, discussing and acting upon key issues, such as funding the government, addressing the need...
Reed Smith
Yesterday, June 15, the California Legislature approved Assembly Bill 102, a bill that drastically overhauls the role of the BOE as a tax administrator, and as the highest administrative appeal body...
Morrison & Foerster LLP
The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements...
Ostrow Reisin Berk & Abrams
In late December 2015, former President Barack Obama signed H.R. 2029, which includes provisions that created the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act).
Reed Smith
In a landmark case titled Valley Forge Towers Apartments N, LP, et al. v. Upper Merion Area School District & Keystone Realty Advisors, LLC, No. 49 MAP 2016, issued July 5, 2017, ...
Foley Hoag LLP
Did someone steal your tax return? You are not alone.
Reed Smith
Washington Governor Jay Inslee signed EHB 2163 July 7, imposing sales and use tax obligations on "remote sellers," "referrers," and "marketplace facilitators" beginning January 1, 2018.
Grant Thornton LLP
Do your partners (or co-owners) want to defer into retirement plans more than $60,000 annually – the current limit for contributions to plans such as 401(k) and profit sharing plans?
Ruchelman PLLC
In Rev. Rul. 91-32, the I.R.S. announced its view that foreign partners in partnerships operating in the U.S. are properly taxed on their capital gains under a look-thru rule to the assets owned by...
Dentons
Serving as a vivid reminder that it is vital that a taxpayer comply strictly and completely with the charitable deduction regulations, the Tax Court recently denied a $33 million charitable deduction...
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