Search Results (10594)
Documents on taxation
Show: results per page
|U.S. Treasury Releases Long-Awaited Final Arbitrage Regulations|
Linda L. D'Onofrio, Vanessa Albert Lowry; Greenberg Traurig, LLP;
August 10, 2016, previously published on August 2, 2016On July 18, 2016, the U.S. Department of the Treasury (Treasury) promulgated long-awaited final regulations (the Final Regulations) under Section 148 of the Internal Revenue Code of 1986, as amended (the Code), relating to arbitrage restrictions that finalize numerous provisions of prior proposed...
|A Little Corporate Housekeeping Can Help Avoid a Big Mess|
Stephen P. Katz; Peckar & Abramson A Professional Corporation;
August 9, 2016, previously published on May 2016Now that tax season is over, and we’ve finally caught a breath after fi ling our tax returns in a timely fashion, it is a good time to consider some corporate housekeeping tips that will help keep intact the limitation of liability that corporate entities provide to their shareholders. While...
|New Proposed Regulations Provide Clarity and Rigidity to Tax-Free Spin-Off Rules|
Josh Prywes, Alejandro Ruiz; Greenberg Traurig, LLP;
August 9, 2016, previously published on July 22, 2016If finalized, newly released proposed Treasury regulations may make spin-offs more difficult to accomplish despite providing important clarity. The proposed regulations tighten the standard for what constitutes an “active trade or business” to qualify for tax-free treatment in a...
|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...
|Quid Pro Quo: When a “Gift” is not a Gift|
Burnet R. Maybank, James P. Rourke; Nexsen Pruet, LLC;
August 5, 2016, previously published on April 8, 2016When it comes to properly documenting property and cash donations, most charities are well-versed with the IRS’ substantiation rules. But equally as important to those rules are the disclosure requirements regarding quid pro quo donations—that is, where the donor receives goods,...
|U.S. Tax Court Again Focuses on Reasonable Compensation|
Douglas Turner Coats; Gordon Feinblatt LLC;
August 5, 2016, previously published on May 2016For the second time in 2016, the United States Tax Court (the “Court”) has issued a decision involving the application of the independent investor test in considering the issue of reasonable compensation for a C corporation. On May 11, 2016, the Court released its decision in H. W....
|Proposed Regulations Would Block Some Spinoffs|
Richard M. Nugent, Linda Z. Swartz, Edward S. Wei; Cadwalader, Wickersham & Taft LLP;
August 5, 2016, previously published on July 15, 2016Proposed regulations issued on July 14, 2016 generally would prevent tax-free spinoffs involving companies with less than 5% active business assets and spinoffs where one company holds a substantial amount of nonbusiness assets and the other company does not. These rules generally would apply to...
|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...
|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.
|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...