Mondaq USA: Tax > Income Tax
Ruchelman PLLC
When a U.S. company acquires foreign targets, the use of a holding company structure abroad may provide certain global tax benefits.
Womble Carlyle
In our first two newsletters, we offered thoughts and predictions on the Trump Legislative Agenda. Here are a few updates:
Grant Thornton LLP
On July 13, 2017, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3 (2017), the U.S. Tax Court held that certain gain recognized by a nonresident partner...
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
At issue before the Tax Court was whether the remaining gain from the redemption of GMM's interest was ECI and therefore subject to U.S. federal income tax.
Foley & Lardner
Moreover, the Grecian Magnesite decision could also be affected by a legislative response.
Shearman & Sterling LLP
The US Tax Court rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in a US business will not be treated as "effectively connected income"...
Cadwalader, Wickersham & Taft LLP
The Democrats vowed they would not back a tax reform plan that "includes tax cuts for the top one percent."
Grant Thornton LLP
On July 13, 2017, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3 (2017), the U.S. Tax Court held that gain recognized by a nonresident partner...
McDermott Will & Emery
The new federal partnership income tax audit rules, scheduled to take effect on January 1, 2018, will have significant implications for the state and local taxation of partnerships and their partners.
Ostrow Reisin Berk & Abrams
Multistate taxation laws are complex and vary from state to state.
Duane Morris LLP
If you use online platforms to rent a spare bedroom, lawnmower, car or bicycle; or to provide car rides or dog walks; or to connect and deliver other goods or services, you are involved in what is sometimes called the sharing economy.
McDermott Will & Emery
The Multistate Tax Commission (MTC) is moving quickly to implement a multistate amnesty program through its current National Nexus Program (NNP) for sellers making sales through marketplaces.
Andrews Kurth LLP
Some state and local governments are attempting to apply new taxes and other charges to publicly traded companies with disclosed pay ratios that exceed certain thresholds.
Grant Thornton LLP
The Ohio legislature recently passed biennial budget legislation including several significant tax provisions. Gov. John Kasich signed the bill on June 30, 2017, vetoing several line items.
McDermott Will & Emery
Not only is the scope of NRWRA's limitation broader with respect to the definition of physical presence, but also on the activities that are limited.
K&L Gates
In a recently published decision, the U.S. Tax Court declined to follow the longstanding position of the U.S. Internal Revenue Service ("IRS"), articulated in Revenue Ruling 91-32
Grant Thornton LLP
On May 31, 2017, the Minnesota Tax Court overturned as unconstitutional the taxation of certain trusts as Minnesota "resident trusts" and held that application of the statutory definition of "resident trust"...
Grant Thornton LLP
On May 2, 2017, the Michigan Tax Tribunal granted a passive holding company's motion for summary disposition and held that it did not have the requisite nexus with the city of Detroit for purposes of the CDIT.
Grant Thornton LLP
On July 6, 2017, the Illinois House of Representatives followed the Senate and voted to override Governor Bruce Rauner's veto of S.B. 9, enacting the state's FY 2017-2018 budget after two years...
Stroock & Stroock & Lavan LLP
Responding to President Donald Trump's Executive Order 13789, which called on the Secretary of the Treasury to submit an interim report identifying any significant tax regulations issued since January 1, 2016...
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Alliott Group (International)
When specific U.S. tax payers choose to expatriate, they can face significant tax consequences and must also consider a number of other issues.
Akin Gump Strauss Hauer & Feld LLP
Recent IRS guidance requires that non-U.S. investment funds currently relying on an FFI agreement for their FATCA compliance must renew such agreement on the IRS website by July 31, 2017...
Stroock & Stroock & Lavan LLP
Responding to President Donald Trump's Executive Order 13789, which called on the Secretary of the Treasury to submit an interim report identifying any significant tax regulations issued since January 1, 2016...
Grant Thornton LLP
On July 6, 2017, the Illinois House of Representatives followed the Senate and voted to override Governor Bruce Rauner's veto of S.B. 9, enacting the state's FY 2017-2018 budget after two years...
Day Pitney LLP
In a significant setback for the IRS, the U.S. Tax Court held in a July 13 opinion that a foreign corporation did not have to pay U.S. tax on gain realized from the redemption of a partnership interest.
Dickinson Wright PLLC
The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative.
Grant Thornton LLP
In Petersen v. Commissioner, 148 T.C. No. 22 (June 13, 2017), the Tax Court addressed the application of Section 267(a)(2) to an S corporation that maintains an employee stock ownership plan (ESOP).
McDermott Will & Emery
Our June 2017 blog posts are available on insidesalt.com, or read each article by clicking on the titles below.
Day Pitney LLP
Massachusetts taxpayers should keep an eye on two developments. First, a proposed constitutional amendment will be on the ballot in 2018.
Morrison & Foerster LLP
On July 11, 2017, the Indiana Tax Court released a decision in E.I. DuPont de Nemours and Company v. Indiana Department of State Revenue.
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