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|Master Limited Partnerships: Proposed Tax Regulations Scale Back Activities Giving Rise to Qualifying Income|
Benjamin G. Clark, Catherine M. Krupka, David T. McIndoe, Daniel R. McKeithen, David A. Roby; Sutherland Asbill & Brennan LLP;
June 25, 2015, previously published on June 24, 2015The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities relating to minerals and natural resources that generate “qualifying...
|IRS Revamps Proposed Issue Price Definition for Municipal Bonds|
Christie L. Martin, Maxwell D. Solet; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
June 25, 2015, previously published on June 23, 2015Treasury and IRS today announced a decision to withdraw the much-criticized portion of the notice of proposed rulemaking published in the Federal Register on September 16, 2013 (the “2013 Proposed Regulations”) related to the definition of issue price for tax-advantaged obligations and...
|IRS Backs Off on Advance|
David B. Shiner; Chuhak & Tecson, P.C.;
June 25, 2015, previously published on June 18, 2015Good lawyering got the IRS to back off the assessment of additional tax on receipt of an advance. Client entered into a three year service contract with Company to sell a new product. Company provided an advance of $100X to Client when he signed the contract. Under the contract, if Client reached...
|Residence Precedence? California State Board of Equalization Considers Issuing Formal Opinion in Taxpayer-Favorable Residency Ruling|
Timothy A. Gustafson, Robert P. Merten; Sutherland Asbill & Brennan LLP;
June 24, 2015, previously published on June 23, 2015The California State Board of Equalization (BOE) has issued a rare ruling on residency topics, finding in favor of individual taxpayers on two issues. First, the BOE found that the taxpayers established domicile in Washington three months earlier than the Franchise Tax Board claimed, because they...
|Ohio Brightens its Bright-Line Test|
David J. Rectenwald; Shumaker, Loop & Kendrick, LLP;
June 24, 2015, previously published on Spring 2015Ohio has a brightline test (the “Test”) for determining when an individual is domiciled in Ohio for purposes of Ohio’s income tax. A bright-line test is an objective test, which is one based upon factual criteria, rather than a subjective test, which is one based upon an...
|Estate of Elkins v. Commissioner of Internal Revenue: Cautionary Tale and Gem|
Moses Luski; Shumaker, Loop & Kendrick, LLP;
June 24, 2015, previously published on Spring 2015In the eternal game of cat and mouse between the taxpayer and the Internal Revenue Service (the “Service”), the case of Estate of James A. Elkins, Jr. v. Commissioner of Internal Revenue, 767 F3d 443 (2014), represents a “cautionary tale” for the Service and a...
|India Parliament Ratifies Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act|
Saionton Basu; Duane Morris;
June 24, 2015, previously published on June 18, 2015On 13 May 2015, the India Parliament ratified the Undisclosed Foreign Income and Assets (Imposition of Tax) Bill, 2015. President Pranab Mukherjee signified his assent on 26 May 2015. In prime, the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (the...
|A Proposed Assessment Is Not an Assessment for Statute of Limitations Purposes in Florida|
Zachary T. Atkins, Open Weaver Banks; Sutherland Asbill & Brennan LLP;
June 24, 2015, previously published on June 23, 2015In a closely followed case, a Florida district court of appeal held that a proposed assessment is not an assessment for statute of limitations purposes. The Florida Department of Revenue generally has three years to “determine and assess” any tax, penalty or interest due. The Department...
|IRS Issues Guidance on Portability|
Bruce A. Rawls; Burr & Forman LLP;
June 24, 2015, previously published on June 2015Last week the IRS issued final regulations that provide guidance on the federal estate and gift tax applicable exclusion amount, in general, as well as the requirements for making a "portability" election.
|Ohio: Supreme Court Allows Tax Exemption For Ernest Angley’s Grace Cathedral Dormitory|
David H. Godenswager, David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
June 24, 2015, previously published on June 18, 2015Earlier this month, in Grace Cathedral, Inc. v. Testa, the Ohio Supreme Court concluded that Grace Cathedral, Inc. was entitled to a tax exemption for 2010 for providing temporary housing free of charge to visitors participating in worship services, reversing the decision of the Board of Tax...