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|C Corp Reasonable Compensation|
Douglas Turner Coats; Gordon Feinblatt LLC;
April 13, 2016, previously published on Spring 2016It is a basic principle of federal tax law that, while a taxpayer is free to organize his affairs as he chooses, once having done so, he must accept the tax consequences of his choice, whether contemplated or not. A medical group that chooses to organize as a C corporation may be forced to...
|Bad Boy (Guaranties), What You Gonna Do?|
Douglas Turner Coats, Y. Jeffrey Spatz; Gordon Feinblatt LLC;
April 13, 2016, previously published on April 2016On February 5, 2016, the Internal Revenue Service (the “Service”) Office of Chief Counsel released memorandum 201606027 (the “Memorandum”) which appears to be contrary to the generally-accepted view that nonrecourse debt will be allocated among all partners of a partnership,...
|Rain Tax Is a Tax, but Synagogue Is Not Exempted from Paying It|
Searle E. Mitnick; Gordon Feinblatt LLC;
April 13, 2016, previously published on March 2016Shaarei Tfiloh Synagogue is one of Baltimore’s most recognizable and beloved religious buildings. Known as “the synagogue in the park,” it was constructed between 1921 and 1927. Most notable is its large copper dome which towers above a stone structure with stained glass windows...
|Brazilian Government Approves Increase in Capital Gains Rates|
S. Wade Angus, Marcello Hallake, Sanjiv K. Kapur, Luis Riesgo; Jones Day;
April 12, 2016, previously published on March 2016In September 2015, the Brazilian federal government proposed a new rule increasing the income tax rates applicable to capital gains payable by certain taxpayers from a transfer or sale of assets or rights, as reported in our Alerts of October 2015 and December 2015. The rule has been approved by...
|First Supreme Court Decision on General Anti-Avoidance Rule Concerning Reorganization Transactions|
Harukuni Ito, Yuichiro Mori, John C. Roebuck, Takako Yako, Toru Yamada; Jones Day;
April 12, 2016, previously published on March 2016On February 29, 2016, the Supreme Court (first petty bench) issued a decision describing the standards for applying the general anti-avoidance rule concerning reorganization transactions under Article 132-2 of the Japanese Corporate Tax Law (the "Anti-Avoidance Rule").
|Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes|
J. Randall Buchanan, Robert S. Chase, Reginald J. Clark, Thomas A. Cullinan, Joseph M. DePew; Sutherland Asbill & Brennan LLP;
April 8, 2016, previously published on April 7, 2016On April 4, the Treasury and the Internal Revenue Service (IRS) released proposed regulations under IRC § 385 (the Proposed Regulations)1 that are intended to combat perceived concerns associated with indebtedness between related group entities. Significantly, the Proposed Regulations apply to...
|New York State Tax Appeals Tribunal Holds that Pricing Information Services Are Taxable|
Jessica A. Eisenmenger, Jeffrey A. Friedman; Sutherland Asbill & Brennan LLP;
April 7, 2016, previously published on April 5, 2016The New York State Tax Appeals Tribunal sustained a determination by a Department of Taxation and Finance Administrative Law Judge that receipts obtained from the sale of retail pricing information services are subject to sales tax. Under New York law, information services are taxable, but services...
|The Home Stretch: Virginia Tax Commissioner Rules that Single Employee Working From Home Creates Nexus|
Open Weaver Banks, Michael G. Kerman; Sutherland Asbill & Brennan LLP;
April 7, 2016, previously published on April 5, 2016The Virginia Tax Commissioner ruled that an out-of-state corporation had nexus with Virginia because an employee performed accounting, human resources, payroll and customer support functions from a home office in Virginia. The Commissioner explained that out-of-state corporations are subject to...
|Section 162(m): Actions that Should be Taken by March 30, 2016, and/or in this Year’s Proxy to Avoid the $1,000,000 Deduction Limitation|
Michael R. Einig, Ian A. Herbert, Leslie A. Klein, Steven B. Lapidus, Mindy B. Leathe; Greenberg Traurig, LLP;
April 7, 2016, previously published on March 22, 2016This GT Alert serves to remind our publicly held clients of things that need to be done early this year to minimize or avoid the application of the deduction limitations imposed by Section 162(m) of the Internal Revenue Code of 1986, as amended. The Alert also provides an overview of the basic...
|Alabama Tax Tribunal Determines Out-of-State Bookseller Has Nexus, Joins "Club"|
Zachary T. Atkins, Eric J. Coffill; Sutherland Asbill & Brennan LLP;
April 7, 2016, previously published on April 6, 2016The Alabama Tax Tribunal concluded that an out-of-state retailer was required to collect and remit use tax on the sales of books and educational materials to in-state teachers and students, and that neither the Due Process Clause nor the Commerce Clause impeded the Alabama Department of...