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|The U.S. Must Avoid This Untested Approach To International Taxes|
Peter A. Barnes, H. David Rosenbloom; Caplin & Drysdale, Chartered;
February 3, 2017, previously published on January 24, 2017Corporate profits are up, unemployment is down, wages are rising, and markets are breaking new records. These all point to a U.S. economy that is more stable than the economies of other developed countries.
|A Review of Code Section 754 and its Tax Consequences|
Janice H. Eiseman; Cummings & Lockwood LLC;
February 3, 2017, previously published on November 2, 2016The purpose of this article is to provide a review of the election provided partnerships under §754.1 Understanding §754 requires an understanding of three other Code sections. Those three sections are: §743(b), §734(b) and §755. Section 754, a very short provision, simply...
|Alberta Investor Tax Credit Opens for Business|
Steven Bodi, Brad J. Pierce, Colin Poon, Michael Saliken; Borden Ladner Gervais LLP;
February 2, 2017, previously published on January 16, 2017On December 15, 2016, the Government of Alberta ("Government") released guidelines providing details of the Alberta Investor Tax Credit ("AITC") program created under the Investing in a Diversified Alberta Economy Act (the "Act"). The Act came into force January 1,...
|Voluntary Disclosure Window Closing for Bitcoin|
Mark E. Matthews, Scott D. Michel; Caplin & Drysdale, Chartered;
January 27, 2017, previously published on December 16, 2016On November 30 2016 a federal court in San Francisco authorised the Internal Revenue Service (IRS) to issue a John Doe summons to Coinbase Inc, which operates a web-based global convertible digital currency wallet and platform and the largest platform in the United States for the conversion of...
|Non-Qualified Deferred Compensation: It’s Still in the Mix|
Michael G. Riley; McDonald Hopkins LLC;
January 26, 2017, previously published on January 13, 2017There are many reasons that companies adopt these plans, but the primary reason for implementing non-qualified deferred compensation plans is to attract and retain talent, usually at the executive level. Many executives are interested in an opportunity to defer current compensation, to defer taxes,...
|Non-Qualified Deferred Compensation: Know It When You See It|
Michael G. Riley; McDonald Hopkins LLC;
January 26, 2017, previously published on January 16, 2017This is a surprisingly tricky question. When people talk about deferred compensation, that’s usually short-hand for “non-qualified” deferred compensation. Generally, this is compensation that is paid in a year after the year it is earned. In the vast majority of cases, the goal is...
|Looking Ahead To 2017|
Pessin Katz Law P.A.;
January 25, 2017, previously published on December 28, 2016Look for Congress to repeal the Medical Device Tax enacted in 2013 as a funding mechanism for the Affordable Care Act (“ACA” or “Obamacare”).
|Transmission Partnership Not Deemed Includible in Consolidated Return and Allowed To Collect Income Tax Allowance in its Rates|
James M. Bushee, James E. Guy, Danielle R. Lowe, Ellen McElroy, Lino Mendiola, Richard P. Noland, Bradley M. Seltzer, Amish M. Shah; Sutherland Asbill & Brennan LLP;
January 25, 2017, previously published on January 25, 2017On January 6, 2017, Texas utility companies organized as pass-through entities, including partnerships, received welcome news regarding their ability (1) not to elect to be treated as a corporation eligible to be included in a consolidated return, regardless of whether such inclusion would be...
|Governor Baker Announces Mid-Year Budget Cuts, Draws Rebuke from Legislature|
Steve Baddour, Dan Connelly, Julie Cox, Max Fathy; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
January 25, 2017, previously published on December 7, 2016On Tuesday, December 6, Governor Charlie Baker, under his Section 9C authority, ordered $98 million in mid-year cuts from the $39.25 billion FY17 state budget. The administration has warned of budget imbalances for months and this action aims at aligning state revenues, which have lagged throughout...
|Financier Worldwide Annual Review: Transfer Pricing 2016 - United States|
J. Clark Armitage; Caplin & Drysdale, Chartered;
January 24, 2017, previously published on November 16, 2016Q. What do you consider to be the most significant transfer pricing changes or developments to have taken place in your region over the past 12 months or so?