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|Income Tax - Transfers of Family Business to Children Tax Free|
Pessin Katz Law P.A.;
July 10, 2014, previously published on June 26, 2014In Bross Trucking, Inc., TC Memo 2014-10, the United States Tax Court ruled that a taxpayer’s wholly-owned corporation that ceased operations due to its difficulty with regulatory authorities had no goodwill. As a result, even though the taxpayer’s sons started a new business that had...
|Detroit Bankruptcy Update: Sixth Circuit Throws Wrench into Restructuring Timetable|
Scott St. Amand, J. Ellsworth Summers; Rogers Towers, P.A.;
July 10, 2014, previously published on July 8, 2014Earlier this month the Sixth Circuit Court of Appeals ruled that the appeal of Syncora Guarantee Inc. must be heard by the lower federal district court before the bankruptcy court may conduct its trial on the city’s proposed Chapter 9 restructuring plan, which is scheduled to begin on August...
|Minnesota Department of Revenue Revises a Release that Discusses Application of Sales Tax to Digital Products|
Sutherland Asbill Brennan LLP;
July 10, 2014, previously published on July 07, 2014The Minnesota Department of Revenue updated its Sales Tax Fact Sheet on digital products to explain that webinars (electronically accessed live or prerecorded audio and audiovisual presentations) are exempt from tax provided the following three requirements are met:
|Control Is Everything|
Pessin Katz Law P.A.;
July 10, 2014, previously published on June 30, 2014In Private Letter Ruling 201423043, (“PLRs” only apply to the taxpayer involved but are often used as “guidance”, and not “precedent”, by taxpayers and the IRS.) the IRS ruled that a surviving spouse could roll over her deceased husband’s Roth IRA payable...
|IRS Modifies Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures|
Scott D. Michel, Zhanna A. Ziering; Caplin & Drysdale, Chartered;
July 9, 2014, previously published on June 23, 2014On June 18, 2014, the IRS unveiled significant changes to both Offshore Voluntary Disclosure Program (OVDP) and Streamlined Filing Compliance Procedures (SFCP). The changes both relax the penalty structure for non-willful behavior but increase it soon for account holders at certain banks. The...
|Don’t Fall Off the New York Estate Tax Cliff|
Phillips Nizer LLP;
July 9, 2014, previously published on June 2014Effective April 1, 2014, the New York estate tax exemption (the “State Basic exemption Amount”) was increased to just over $2,000,000 and is set to gradually increase over the next few years. (See chart on page 2.) We estimate that the State Basic Exemption Amount will be excess of...
|New Florida Limited Liability Act Is Effective|
Berger Singerman LLP;
July 9, 2014, previously published on June 25, 2014The Florida Revised Limited Liability Act (the “New Florida LLC Act”) is now effective for all limited liability companies organized in Florida on or after January 1, 2014. A limited liability company organized in Florida prior to January 1, 2014 will continue to be governed by the old...
|New Jersey Tax Sale Law Gives Purchaser of a Tax Sale Certificate a Tax Lien on the Underlying Property|
Duane Morris LLP;
July 9, 2014, previously published on June 30, 2014The New Jersey Supreme Court, in In re: Princeton Office Park, L.P. v. Plymouth Park Tax Services, LLC, determined that under the Tax Sale Law, N.J.S.A. §§ 54:5-1 to -137, a purchaser of a tax sale certificate acquires a tax lien, not a lien securing the property owner's obligation to pay...
|After All the Preparation, It’s Finally Here: FATCA Becomes Effective July 1, 2014|
Dennis L. Allen, Robert S. Chase, Thomas A. Gick, Jerome B. Libin, Jeffrey H. Mace; Sutherland Asbill & Brennan LLP;
July 9, 2014, previously published on June 30, 2014More than four years after Congress enacted the Hiring Incentives to Restore Employment Act of 2010, Pub. L. 111-147, which added the Foreign Account Tax Compliance Act (FATCA) provisions to the Internal Revenue Code, FATCA will become effective on July 1, 2014. While the importance of this date...
|Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program|
Jennifer Lynn Bell, Matthew D. Lee, Jeffrey M. Rosenfeld; Blank Rome LLP;
July 9, 2014, previously published on June 2014Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts (“FBAR”) by June 30th of each year. In addition to requiring the...