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1
U.S. Tax Court Bounces Rev. Rul. 91-32: Sales Of Partnership Interests By Foreign Partners May Not Be Subject To U.S. Tax
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.
United States
27 Jul 2017
2
Have Yourself A Very Trumpy Tax Plan
Well, we've had the big reveal and the administration's new tax plan is out. This plan, announced with a great deal of fanfare, feels more like a campaign promise than an actual executable plan.
United States
26 Jul 2017
3
New Illinois Budget Bill Imposes Major Tax Increases And Unclaimed Property Burdens On Businesses
Overriding Governor Bruce Rauner's veto, the new Illinois budget bill passed on July 6, 2017, imposes some major income tax increases for both corporate and non-corporate businesses,...
United States
25 Jul 2017
4
Massachusetts Appellate Tax Board Denies Multiple Points Of Use Sales Tax Refund Claims
The Massachusetts Appellate Tax Board ("ATB") has issued an order denying three sales tax refund claims involving multiple points of use ("MPU") sourcing. In each case, vendors had filed refund claims...
United States
24 Jul 2017
5
Tax Court Declines To Follow IRS Ruling On Foreign Partner's Redemption Gain
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.
United States
24 Jul 2017
6
Senate Finance Committee To Discuss Tax Reform
The United States Senate Committee on Finance (the "Committee") will hold hearings on July 18, 2017 to discuss options for overhauling the tax code and to consider the nomination of...
United States
24 Jul 2017
7
Proposed Regulations Limiting Discounts On Family Gifts Targeted For Reform
Last summer, we discussed the IRS's issuance of new Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts made to family members.
United States
24 Jul 2017
8
What Is Minimal Substantial Nexus?
Can a seller have nexus with a state – so as to be obligated to collect and remit that state's sales and use taxes – only in connection with certain sales that seller makes into that state?
United States
24 Jul 2017
9
Indiana Tax Court Allows Deductions For Interest Paid On Intercompany Loans And Holds That Gain From Sale Of Partnership Was Nonbusiness Income
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.
United States
21 Jul 2017
10
Renewal Of U.S. FATCA Registration For Certain Investment Funds By Monday, July 31, 2017
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...
United States
21 Jul 2017
11
Developments In FICA And Self-Employment Tax Affect Partners And S Corporations
I was recently honored to serve as a guest columnist in the June 2017 "Shop Talk" column in WG&L's Journal of Taxation.
United States
21 Jul 2017
12
Treasury Identifies Eight Regulations Subject To Modification And Potential Repeal
The Treasury Department on July 7 issued Notice 2017-38 which identifies eight regulations — including those issued under Section 385 — that could be subject to some reform, including modification...
United States
21 Jul 2017
13
Beverage Tax Wars Continue As Parties Head Back To Court For A Preliminary Injunction Hearing On The Cook County, Illinois Tax
A legal challenge to Cook County Illinois Sweetened Beverage Tax (Tax) heads back to circuit court today for a hearing on the plaintiffs' motion for preliminary injunction.
United States
21 Jul 2017
14
IRS Identifies 8 Burdensome Regulations For Reform
Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden...
United States
21 Jul 2017
15
Transfer Pricing Times: OECD Releases Discussion Draft On Hard-To-Value Intangibles
In this edition: the OECD releases discussion draft on hard-to-value intangibles, Australia issues risk framework for evaluating intercompany loans, recent transfer pricing developments in India, ...
Worldwide
21 Jul 2017
16
Income Taxes And Your Divorce
When getting a divorce, you should be certain to discuss with your accountant the various tax issues that need to be considered.
United States
20 Jul 2017
17
Finishing SALT: Inside SALT's Monthly Recap
Our June 2017 blog posts are available on insidesalt.com, or read each article by clicking on the titles below.
United States
20 Jul 2017
18
Treasury Dept. Identifies 8 "Significant Tax Regulations" For Review To Reduce Burden
As instructed by President Donald Trump's Executive Order 13789 from April 21, 2017, the U.S. Department of the Treasury announced on July 7...
United States
20 Jul 2017
19
Kentucky Supreme Court Strikes Down Provision Of State's Telecommunications Tax
The Kentucky Supreme Court recently held a portion of the state's Multichannel Video Programming and Communications Services Tax (the "Telecommunications Tax" or "Telecom Tax")...
United States
20 Jul 2017
20
U.S. Tax Court Exempts Gain On Sale Of Interests In ECI-Generating Partnerships
The Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co., SA (149 TC No. 3 (2017)) (Grecian Magnesite) has determined that gain from a non-U.S. corporation's sale of an interest in a U.S. partnership ...
United States
19 Jul 2017
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