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|The IRS’ Case Against Sumner Redstone, Former Head Of CBS And Viacom, Demonstrates That The Statute Of Limitations For Gift Tax On Unreported Gifts Never Runs Out.|
McGrath North Mullin Kratz PC LLO;
September 22, 2016, previously published on Second Quarter 2016In a recent federal case, the U.S. Tax Court held that Sumner Redstone, the former head of CBS and Viacom, owed nearly $750,000 in gift tax on 1972 gifts to his children of stock in a family corporation (“Gift Tax Shares”). Furthermore, because the tax was due in 1972, the interest on...
|A "Quest" for Certainty - Court of Appeal Affirms Louisiana Was a "Location-of-Performance" State All Along|
John F. Fletcher, Justin B. Stone; Jones Walker LLP;
September 22, 2016, previously published on September 12, 2016In Quest Diagnostics, the Louisiana Court of Appeal, First Circuit recently confirmed that Louisiana was a "location-of-performance" state when sourcing service-based receipts for corporate income tax apportionment purposes. 1We say "was" because the Louisiana Legislature...
|Introduction of Stringent Transfer Pricing Documentation Requirement|
Koichi Inoue, Kyosuke Katahira, Taku Osawa, Takako Yako; Jones Day;
September 22, 2016, previously published on September 2016A recent 2016 tax reform in Japan ("Reform") has introduced stringent Japanese Transfer Pricing Documentation Requirements, which require the preparation/filing of: (i) a Master File, (ii) a Country-by-Country Report, and (iii) a Local File, as well as (iv) a "Notification of the...
|Nebraska Court Of Appeals Rules That, If Land Is Held Within A Revocable Trust, An Appeal Of A Property Tax Valuation To That Court Must Be Filed By An Attorney|
McGrath North Mullin Kratz PC LLO;
September 22, 2016, previously published on Second Quarter 2016In a recent court case, the Nebraska Court of Appeals considered whether a couple who, as part of their estate planning, placed real property into a revocable living trust could themselves file a property tax appeal to that Court.
|The Pros and Cons of Entity Structures|
Jason W. Klimek; Boylan Code, LLP;
September 21, 2016, previously published on September 2, 2016You’ve decided that you want to form a company. Great! Maybe you want to form a simple C corporation, but you’ve heard something about “double taxation,” and you certainly don’t want to pay taxes twice. You’ve also heard people, in passing, mention S...
|Ghislain Poulin and Herman Turgeon v. Her Majesty the Queen, 2016 DTC 1129|
Joseph Hovsep Takhmizdjian; Borden Ladner Gervais LLP;
September 21, 2016, previously published on September 13, 2016Facts: L’Amiante’s corporate structure was reorganized to facilitate the departure of the taxpayer Mr. Poulin, and to integrate Mr. Hélie into the company. Mr. Poulin, Mr. Turgeon, and Mr. Hélie each incorporated a corporation (Gestion Poulin Gestion Turgeon, and Gestion...
|IRS Provides Benefit Plan Relief to Louisiana Flood Victims|
Timothy P. Brechtel, Ricardo X. Carlo, Susan K. Donahoe Chambers; Jones Walker LLP;
September 14, 2016, previously published on September 6, 2016On August 14, 2016, President Obama declared a major disaster in the State of Louisiana due to the severe storms and flooding that took place in several State parishes ("Louisiana Storms"). Following the declaration, the Internal Revenue Service (IRS) issued guidance postponing certain...
|The Road Not Taken Leads to Forfeiture of an Appeal|
Bruce P. Merenstein; Schnader Harrison Segal & Lewis LLP;
September 14, 2016, previously published on September 2016Earlier this week, the Superior Court of Pennsylvania issued a short, precedential opinion, reiterating that there are “no exceptions” to the deadline for filing a notice of appeal from a trial court’s final judgment.
|Federal Tax Return Filing and Payment Relief|
Jonathan R. Katz, B. Trevor Wilson; Jones Walker LLP;
September 14, 2016, previously published on September 8, 2016On August 14, 2016, President Obama declared several parishes in southern Louisiana major disaster areas because of the severe storms and flooding that occurred. These parishes included Acadia, Ascension, Avoyelles, East Baton Rouge, East Feliciana, Evangeline, Iberia, Iberville, Jefferson Davis,...
|Missed the IRA Rollover Window? New Revenue Procedure May Save Stress and Money|
Timothy M. White; Smith Haughey Rice & Roegge, P.C.;
September 14, 2016, previously published on August 31, 2016On August 24, 2016, the IRS issued a new revenue procedure that has the potential to save taxpayers a lot of stress and money. In general, when a taxpayer takes a distribution from an IRA or other qualified plan, that distribution must be included in the taxpayer’s gross income unless the...