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|IRS Clarifies Income Inclusion Rules in Section 50(d)(5) for Partnerships and S Corporations|
Jonathan R. Katz, Ravinder P. Khinda; Jones Walker LLP;
August 11, 2016, previously published on July 2016On July 21, 2016, the IRS released temporary and proposed regulations that address income inclusion with respect to lessees of investment tax credit property when owners treat the lessees as having acquired the property for investment tax credit purposes. The rules apply when a partnership or an S...
|New Changes to Florida Beverage Laws Start Today|
Jacqueline Bozzuto, Tara L. Tedrow; Lowndes, Drosdick, Doster, Kantor & Reed Professional Association;
August 10, 2016, previously published on July 1, 2016Changes to Florida’s Beverage Laws have drawn attention and controversy over recent years as groups ranging from small craft breweries to major retail vendors have lobbied for legislative amendments to the State’s regulations. As of July 1, 2016, a host of changes to Florida’s...
|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...
|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...
|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...
|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.
|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,...
|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...
|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.
|What does Brexit mean for the European CLO Market?|
Adam Blakemore, Alec J. Burnside, Robert Cannon, Neil Macleod, Claire Suzanne Puddicombe; Cadwalader, Wickersham & Taft LLP;
August 5, 2016, previously published on June 27, 2016In its referendum held on 23 June 2016, the UK voted to leave the European Union (“Brexit”). On the following day, David Cameron announced that he will resign as Prime Minister on the election of a new Conservative Party leader and that such leader should be elected prior to the...