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|New Tax Law Allows Some to Avoid Paying Tax on the Sale of their Business|
Warren P. Kean; Shumaker, Loop & Kendrick, LLP;
August 5, 2016, previously published on June 2016At the end of last year, the President signed into law the ability of some investors to not pay tax on the sale of “qualified small business stock” (“QSBS”) acquired after September 27, 2010 and held for more than five years. Under the new law (which permanently extends this...
|Proposed QI Agreement Addresses Cascading Withholding on Dividend Equivalents|
Brian Foster, Mark P. Howe, Steven Lofchie, Jason D. Schwartz, Ray Shirazi; Cadwalader, Wickersham & Taft LLP;
August 5, 2016, previously published on July 5, 2016On July 1, the U.S. Internal Revenue Service issued Notice 2016-42, which proposes changes to the qualified intermediary (QI) agreement to address cascading U.S. withholding tax on dividends and “dividend equivalents” received and paid by qualified derivatives dealers (QDDs) with...
|TREASURY TREMORS: The Ground is Shifting with Respect to the Allocation of Partnership Liabilities to Partners|
Douglas Turner Coats; Gordon Feinblatt LLC;
August 5, 2016, previously published on March 2016On January 29, 2014, the Treasury Department issued proposed regulations under Internal Revenue Code Section 752, which, if adopted as proposed, would significantly alter the manner in which partnership liabilities are allocated to partners and would particularly affect the real estate industry.
|Unfair Apportionment in Arkansas: ALJ Requires Taxpayer to Use Marked-Based Method to Apportion Services Income|
Chris M. Mehrmann, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
August 5, 2016, previously published on August 1, 2016An administrative law judge (ALJ) of the Arkansas Department of Finance and Administration upheld the denial of a taxpayer’s corporate income tax refund claim, after the taxpayer attempted to amend its returns to apply the cost of performance method of sourcing income.
|Recent Legislation will Require Changes to Most Partnership and Operating Agreements|
Michael S. McGowan; Shumaker, Loop & Kendrick, LLP;
August 5, 2016, previously published on June 2016The Bipartisan Budget Act of 2015 (the “Act”) replaced the existing partnership audit rules with a dramatically different set of rules that will be applicable to the first partnership tax year beginning after 2017. For calendar year partnerships, these rules will be effective for the...
|Japanese 2016 Tax Reforms|
Eric N. Roose; Withers Bergman LLP;
August 5, 2016, previously published on July 13, 2016Consistent with annual procedures, the Japanese government proposed Japanese tax reforms for 2016 last December. Several of the proposed reforms are focused on further advancing the overall economic reform program of the coalition government led by Prime Minister Abe (often referred to as...
|New Requirement for Organizations Intending to Operate under Section 501(c)(4): Submit Form 8976|
Suzanne G. Odom; Nexsen Pruet, LLC;
August 3, 2016, previously published on July 19, 2016On July 11th, the Internal Revenue Service issued an Exempt Organizations Update regarding a new requirement for organizations intending to operate under Section 501(c)(4).
|The Story of Lucky: Section 1031 Exchanges Can Be Used In The Context of the Sale of Tangible Personal Property|
Laurence E. Fundler; Greenbaum, Rowe, Smith & Davis LLP;
August 3, 2016, previously published on August 2016It is worth noting that the same opportunities and rules of Section 1031 that apply to the sale of real estate also can apply to the sale of tangible personal property such as coins, artwork or other collectibles.
|Will Your Non-Profit Hospital Pay Property Taxes in New Jersey?|
Duane Morris LLP;
August 2, 2016, previously published on March 23, 2016In the wake of the June 25, 2015, decision of the New Jersey Tax Court in AHS Hospital Corp., d/b/a Morristown Memorial Hospital v. Town of Morristown, and the hospital’s subsequent $15.5 million settlement with the town, more than a dozen municipalities are pursuing tax appeals that...
|Investing into India: Mauritius and Beyond|
Mahesh Kumar; Withers Bergman LLP;
July 29, 2016, previously published on July 13, 2016Mauritius and India recently signed a protocol phasing out the Capital Gains Tax exemption available under their double-tax treaty with respect to the sale of Indian securities. This is a major development impacting both Mauritian and Singapore investment structures which currently contribute...