Mondaq USA: Tax
Ropes & Gray LLP
On March 21, 2019, the IRS announced it is temporarily suspending two revenue rulings addressing tax-free spinoffs.
Proskauer Rose LLP
On March 15, 2019, the U.S. Court of Appeals for the Seventh Circuit held in Gaylor v. Mnuchin that the tax exemption for "ministers of the gospel" (defined below) under Section 107(2)
Moritt, Hock & Hamroff LLP
Rev. Rul. 57-464 and Rev. Rul. 57-492 have recently been suspended pending completion of a study by the Treasury Department and Internal Revenue Service concerning the five-year,
Mayer Brown
As previously discussed on this blog, Maryland, in 2017, become the first state in the county to offer an income tax credit for energy storage systems and, to our knowledge,
Kramer Levin Naftalis & Frankel LLP
As part of the 2020 budget, the New York State Senate and Assembly enacted new revenue legislation, which included an increase to New York State's transfer tax and mansion tax on transfers
Ruchelman PLLC
Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities ...
Ruchelman PLLC
The U.S. Federal deficit is expected to reach $1 trillion in 2019. Meanwhile, a hedge fund billionaire recently purchased a New York City condominium ...
Dickinson Wright PLLC
On March 28, 2019, U.S. Senate Finance Committee Chairman Chuck Grassley (R-IA) and Senator Ron Wyden (D-OR) introduced new tax legislation referred to as the Taxpayer First Act of 2019.
Ropes & Gray LLP
In an alarming development for some private equity funds, the Court of Justice of the European Union (the CJEU) has issued two judgments in the combined N Luxembourg 1 (Case C-115/16),
Ruchelman PLLC
Nothing is certain in this world, except death and taxes – and even taxes are subject to change.
Ruchelman PLLC
When foreign corporations have certain activities in the U.S., the question often arises as to whether a taxable presence exists in the U.S. for Federal income tax purposes.
Arnold & Porter
The US Internal Revenue Service and the US Department of Treasury recently released proposed regulations that may provide relief to individual US Shareholders of "controlled foreign corporations" ...
Jeffer Mangels Butler & Mitchell LLP
Different rates and withholding amounts generally apply to these two categories of income, as described below.
Ostrow Reisin Berk & Abrams
A vacation home can be many things to different people.
Ostrow Reisin Berk & Abrams
Any interest in excess of those amounts is limited to 30% of adjusted taxable income.
Ostrow Reisin Berk & Abrams
Here are four major changes that are likely to save taxes for domestic manufacturers.
Duff and Phelps
Now, it's time to step back, take a deep breath and assess just where things stand on a state-by-state basis.
Arnold & Porter
The Tax Cuts and Jobs Act (TCJA), signed into law on December 22, 2017, was the most significant change in the federal tax law since 1986. Although the TCJA ...
Womble Bond Dickinson
The 2017 Tax Cut and Jobs Act ("TCJA") introduced a number of provisions that fundamentally change the way that the US taxes income from the foreign operations of US groups
Duff and Phelps
On March 1, 2019, the APMA program announced the introduction of a new Excel-based model which taxpayers that are seeking an APA may be required to complete as part of the APA process.
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Ruchelman PLLC
On August 8, 2018, the I.R.S. issued much-awaited proposed regulations under new Code §199A, which was added by the 2017 Tax Cuts and Jobs Act. The provision was initially discussed in detail in our February 2018 edition.
Duane Morris LLP
In 2014, Elon Musk announced that he was "open-sourcing" Tesla's patents.
Womble Bond Dickinson
Were the Beatles still recording today, they might have to add this verse to Taxman.
Proskauer Rose LLP
The passthrough deduction provides a maximum effective rate of 29.6%.
Ruchelman PLLC
The I.R.S. recently issued Notice 2018-28, announcing that it intends to release regulations on various issues pertaining to the limitation on the deductibility of certain interest payments...
Davies Ward Phillips & Vineberg
U.S. taxpayers will remember 2018 as the year spent coming to terms with the tax reform legislation enacted at the end of 2017, known as the Tax Cuts and Jobs Act (TCJA).
Jones Day
A recent written auditor request indicates an aggressive position and differing treatment on previously exempt Illinois business-to-business property.
Fenwick & West LLP
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts
Ropes & Gray LLP
On December 21, 2018, IRS and Treasury issued final regulations implementing the partnership audit regime (T.D. 9844).
Duff and Phelps
On March 12, 2019, the European Union updated the EU Blacklist of Non-Cooperative Jurisdictions in Taxation Matters and added 10 new jurisdictions to the list, including Aruba, Barbados, Belize, Bermuda, ...
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