Mondaq USA: Tax
Although the focus of proposed regulations issued by the US Internal Revenue Service (IRS) on August 9, 2019, may have been on "cloud computing," the proposed regulations provide significant new guidance on the taxation of transfers of digital content as well.
Ropes & Gray LLP
In the wake of the IRS' Ninth Circuit victory in Altera Corporation v. Commissioner, 926 F.3d 1061 (9th Circuit 2019), the IRS' Large Business and International (LB&I) Division
Eide Bailly LLP
On May 30, 2019, Minnesota Governor Tim Walz signed an omnibus tax bill that will impact most Minnesota taxpayers.
Mayer Brown
Prior to the Tax Cuts and Jobs Act of 2017 ("TCJA"), the appeal of cost sharing was driven largely by the deferral of U.S. taxation on foreign earnings.
Lewis Roca Rothgerber Christie LLP
On May 31, 2019, Governor Doug Ducey signed Arizona H.B. 2757, which updated Arizona's income tax code to conform to the 2017 federal Tax Cuts and Jobs Act (TCJA).
Withers LLP
For a number of years, US taxpayers have invested in a variety of convertible virtual currencies also referred to as CVCs – cryptocurrencies being forms of CVCs that use cryptography –
Morrison & Foerster LLP
The New York State Department of Taxation and Finance has released revisions to its draft business corporate franchise tax regulations interpreting
Ostrow Reisin Berk & Abrams
The Roth IRA is an attractive savings vehicle, offering tax-free retirement income and other significant benefits. Unfortunately, income limitations prevent many people
Davies Ward Phillips & Vineberg
A foreign corporation whose ownership meets these tests is known as a CFC.
Withers LLP
Global tax transparency is a pretty easy idea to get behind; in societies with a functioning tax authority, it should be unlawful for a taxpayer to squirrel assets away from proper scrutiny.
Ruchelman PLLC
Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations:
Dickinson Wright PLLC
IRC ง 1400Z-2, under The Tax Cuts and Jobs Act of 2017, established an investment program designed to provide preferential tax treatment for investment in developments located within certain
Squire Patton Boggs LLP
Contrary to its name, The Tax Cuts and Jobs Act resulted in a tax increase for certain entities. For example, certain well-endowed private universities
Thompson Coburn LLP
On July 3, 2019, the Internal Revenue Service ("IRS") issued proposed regulations under Internal Revenue Code section 4968.
Day Pitney LLP
In response, the IRS released final regulations on June 11 designed to prohibit taxpayers from circumventing this type of SALT limitation.
Squire Patton Boggs LLP
On June 10, 2019, Senators Michael Bennet (D-CO) and Rob Portman (R-OH) introduced Senate Bill 1763 (the "Carbon Capture Bill"), which, if passed, would allow
Day Pitney LLP
The mansion tax is a separate tax imposed on transfers of residential real property located in New York State.
Eisner Amper
The goal of this campaign is to increase awareness and compliance with the law as supported by several court decisions.
Recently, the IRS announced that it was targeting individual taxpayers who previously participating in its Offshore Voluntary Disclosure Program
Lewis Roca Rothgerber Christie LLP
On May 31, 2019, Governor Doug Ducey signed Arizona H.B. 2757 adopting economic nexus standards for internet sales made into Arizona. This change was in direct response to the US Supreme Court's
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Ruchelman PLLC
On August 8, 2018, the I.R.S. issued much-awaited proposed regulations under new Code ง199A, which was added by the 2017 Tax Cuts and Jobs Act. The provision was initially discussed in detail in our February 2018 edition.
Milbank LLP
Two years have passed since Treasury and the IRS first announced that they were working on guidance relating to the basis of grantor trust assets at death.
Holland & Knight
In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance)
Proskauer Rose LLP
The Supreme Court ruled unanimously on June 21, 2019, that a trust beneficiary's residence in a State, standing alone, is not sufficient for that State to impose income tax on that trust.
Duff and Phelps
The Medtronic case is slated to head back to court in April of 2020 in accordance with an order from the tax court.
Recently, the IRS announced that it was targeting individual taxpayers who previously participating in its Offshore Voluntary Disclosure Program
Gibson, Dunn & Crutcher
This webcast brings together a diverse panel of professionals in electric utility tax issues to discuss the impact of the 2017 Federal Tax Cuts and Jobs Act ("TCJA") on electric utilities
Butler Snow LLP
By now most Mississippians have at least heard of the New Markets Tax Credit ("NMTC") Program
The Office of the U.S. Trade Representative ("USTR") announced on July 10 the initiation of an investigation under Section 301 of the Trade Act of 1974 into France's digital services tax ("DST").
Morrison & Foerster LLP
A Third Department decision denying deductibility of insurance premiums paid to a captive insurance company, upholding the decision of the New York State Tax Appeals Tribunal...
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