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1
MoFo New York Tax Insights - Volume 10, Issue 4
Welcome to the latest issue of New York Tax Insights.
United States
23 Apr 2019
2
IRS Announces Expanded Penalty Waiver For Individuals With Underpayment Of 2018 Estimated Income Taxes
With the 2018 deadline for filing of individual income tax returns just around the corner, taxpayers should be aware of the recent announcement by the IRS of expanded relief from penalties for individuals whose 2018...
United States
23 Apr 2019
3
ICI Opposes NY State Bills To Reduce Rebate Of Stock Transfer Sales Tax
The Investment Company Institute ("ICI") expressed opposition to New York State bills that would reduce the rebate of stock transfer sales tax from 100 percent to 60 percent.
United States
23 Apr 2019
4
Legal Update: Section 956's "Deemed Dividend" Rules: An Update For Lenders On Proposed Changes
Section 956 of the US Internal Revenue Code ("Section 956") has historically loomed large in the context of finance transactions because it limited the ability of US borrowers to use overseas assets
United States
23 Apr 2019
5
Attorney Robert J. Misey Jr. Weighs In On Code Sec. 962 Election
Attorney Robert J. Misey, Jr. offers advice published in the December/January (2018) Journal of Tax Practice & Procedure
United States
22 Apr 2019
6
New York State Transfer Tax Changes
New York State has made changes to the State real estate transfer taxes that will apply to conveyances occurring on or after July 1, 2019
United States
22 Apr 2019
7
IRS Suspends Prior Guidance Limiting Tax-Free Spinoffs
On March 21, 2019, the IRS announced it is temporarily suspending two revenue rulings addressing tax-free spinoffs.
United States
17 Apr 2019
8
Parsonage Exclusion Found By Seventh Circuit To Be Constitutional
On March 15, 2019, the U.S. Court of Appeals for the Seventh Circuit held in Gaylor v. Mnuchin that the tax exemption for "ministers of the gospel" (defined below) under Section 107(2)
United States
17 Apr 2019
9
Is Income Generation Required For A Business To Qualify As An Active Trade Or Business For Successful Section 355 Spin Off? IRS And The Treasury Department Are Reviewing.
Rev. Rul. 57-464 and Rev. Rul. 57-492 have recently been suspended pending completion of a study by the Treasury Department and Internal Revenue Service concerning the five-year,
United States
16 Apr 2019
10
Maryland's Energy Storage Tax Credit Turns Two
As previously discussed on this blog, Maryland, in 2017, become the first state in the county to offer an income tax credit for energy storage systems and, to our knowledge,
United States
15 Apr 2019
11
Important Changes To NYS Transfer And Mansion Taxes
As part of the 2020 budget, the New York State Senate and Assembly enacted new revenue legislation, which included an increase to New York State's transfer tax and mansion tax on transfers
United States
12 Apr 2019
12
Who's Got The B.E.A.T.? Special Treatment For Certain Expenses And Industries
Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities ...
United States
12 Apr 2019
13
Democrats Turn To Tax Reform To Reduce Wealth Disparity
The U.S. Federal deficit is expected to reach $1 trillion in 2019. Meanwhile, a hedge fund billionaire recently purchased a New York City condominium ...
United States
12 Apr 2019
14
New Tax Bill Introduced To Improve IRS And Taxpayer Protections
On March 28, 2019, U.S. Senate Finance Committee Chairman Chuck Grassley (R-IA) and Senator Ron Wyden (D-OR) introduced new tax legislation referred to as the Taxpayer First Act of 2019.
United States
12 Apr 2019
15
The Danish Conduit Cases: A Landmark Ruling On Withholding Tax And Abuse Of Rights
In an alarming development for some private equity funds, the Court of Justice of the European Union (the CJEU) has issued two judgments in the combined N Luxembourg 1 (Case C-115/16),
United States
11 Apr 2019
16
More Permanent Establishments: The Dwindling Preparatory And Auxiliary Activities Exception
Nothing is certain in this world, except death and taxes – and even taxes are subject to change.
United States
11 Apr 2019
17
The I.R.S. Approach To Dependent Agent Status
When foreign corporations have certain activities in the U.S., the question often arises as to whether a taxable presence exists in the U.S. for Federal income tax purposes.
United States
11 Apr 2019
18
IRS Revises EIN Application Process, Increasing Burden On Non-U.S. Taxpayers
On March 27, the IRS announced that taxpayers can no longer request an employer identification number unless the "responsible party" named on the application has a Social Security number.
United States
11 Apr 2019
19
US Treasury Issues Proposed Regulations On The Beneficial IRC Section 250 Corporate Tax Deduction Related To Export Sales Of Property And Services
US Treasury has now published detailed guidance on a significant US corporate tax rate benefit for any US company that conducts direct sales of property and/or services to foreign persons for foreign
United States
10 Apr 2019
20
Transfer Pricing Times: IRS Advance Pricing And Mutual Agreement Program Releases Annual Report
On March 1, 2019, the APMA program announced the introduction of a new Excel-based model which taxpayers that are seeking an APA may be required to complete as part of the APA process.
Worldwide
9 Apr 2019
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