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|Should You Rely On The IRS’ Thoughts Today When Planning For Your Spouse’s Future?|
Michael D. Shelton; Smith Haughey Rice & Roegge, P.C.;
August 29, 2014, previously published on August 18, 2014For many people retirement assets such as Individual Retirement Accounts (IRA) make up the largest portion of their wealth. IRAs are the assets that you hope to consume during your retirement years. You and your spouse worked hard to save these assets and, in many cases, you probably consider them...
|Administrative and Legislative Options to Address US Corporate Inversions|
David M. McIntosh, Anthony "Toby" Moffett; Mayer Brown LLP;
August 29, 2014, previously published on August 28, 2014The topic of tax incentives for US corporations seeking to “invert” and become a subsidiary of a foreign corporation is receiving heightened attention in Congress and federal agencies.
|IRS Issues New Guidance Regarding Beginning of Construction Requirement for Production Tax Credit (PTC) / Investment Tax Credit (ITC)|
Gregory J. Blasi; Leech Tishman;
August 28, 2014, previously published on August 14, 2014The IRS recently issued new guidance (IRS Notice 2014-46) with respect to the ability to claim the PTC/ITC for qualified projects which began construction before January 1, 2014. The current guidance builds on the previous two notices but does add some additional items which should make it easier...
|Non-Dischargeable Tax Debt Not Special Class of Unsecured Creditors|
Scott St. Amand, J. Ellsworth Summers; Rogers Towers, P.A.;
August 28, 2014, previously published on August 26, 2014In numerous previous posts, we have noted that the purpose of the Bankruptcy Code is to help the “honest but unfortunate debtor.” Like gerrymandering, certain “creative” debtors have attempted to classify their non-dischargeable debt as a separate, special class of unsecured...
|IRS Releases New Guidance on Beginning of Construction|
John A. Eliason, Kurt R. Rempe; Foley & Lardner LLP;
August 27, 2014, previously published on August 22, 2014The IRS recently released Notice 2014-46 (the Notice) which provides welcome guidance to tax equity investors and developers on the construction of wind, geothermal, biomass, landfill gas and certain hydropower and marine hydrokinetic energy projects for purposes of qualifying for the section 45...
|Liechtenstein Disclosure Facility (LDF) - HMRC Restricts Favourable Terms|
Judith Ingham, Justine Markovitz; Withers Bergman LLP;
August 27, 2014, previously published on August 22, 2014On 14 August 2014 HM Revenue & Customs (‘HMRC’) announced a number of changes to the terms of the LDF affecting the ability of certain taxpayers who are not already registered to benefit fully from the advantageous terms.
|HMRC Removes Some Advantages of Voluntary Disclosure|
Tim George, Tessa Lorimer, Maurice Martin; Withers Bergman LLP;
August 27, 2014, previously published on August 20, 2014On 14th August 2014 HMRC announced a number of significant changes to the Liechtenstein Disclosure Facility (LDF) which have removed some of the advantages available to those individuals who still have undisclosed tax liabilities to HMRC. The original purpose of the LDF when it was launched back in...
|Colorado: Appellate Court Finds in Favor of Natural Gas Company in Sales Tax Exemption Dispute|
McDonald Hopkins LLC;
August 26, 2014, previously published on August 21, 2014The Court of Appeals of Colorado affirmed a lower court ruling providing that pipelines and fittings located in one of Colorado’s enterprise zones, which are used to gather and deliver natural gas from a taxpayer’s wells to its’ processing facilities, qualify for Colorado’s...
|State Lawmakers Not Blowing Smoke When It Comes To Taxing E-Cigarettes|
McDonald Hopkins LLC;
August 26, 2014, previously published on August 21, 2014The use of e-cigarettes is on the rise, and lawmakers are moving in to regulate and tax them. According to the Centers for Disease Control and Prevention, “about one in five adult smokers tried an e-cigarette between 2010 and 2011.” Most e-cigarette users claim they use them to reduce...
|IRS Relaxes and Clarifies Renewable Energy Tax Credit Eligibility Requirements for Projects Under Construction|
Mintz Levin Cohn Ferris Glovsky Popeo P.C.;
August 25, 2014, previously published on August 12, 2014On August 8, 2014, the Internal Revenue Service (IRS) issued Notice 2014-46 in response to continued industry requests for clarification on several aspects of the renewable electricity Production Tax Credit (PTC) under section 45, or the energy Investment Tax Credit under section 48 in lieu of the...