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Review of incorporation of a partnership: Rev. Rul. 84-111, 1984-2 c.b. 88.

Fox Rothschild LLP
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USA
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August 9 2010

At times it may be desirable to convert an entity taxable as a partnership, such as a limited liability company having more than 1 member or a limited partnership, into a corporation for federal income tax purposes

New 2010 Tax Relief Act addresses and extends rules regarding payments between related controlled foreign corporations under the foreign personal holding company rules

Fox Rothschild LLP
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USA
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December 18 2010

Under the controlled foreign corporation rules, ie, a foreign corporation defined under 957(a) as owned more than 50 of its combined voting power or value is owned by 10 (or such higher percentage) by U.S. shareholders on any day of the taxable year that is involved

New 2010 Tax Relief Act extends Subpart F exception for active financing income extended through tax years beginning before 2012

Fox Rothschild LLP
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USA
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December 18 2010

Under the Subpart F rules, 951-964, 10 or greater US shareholders of a controlled foreign corporation ("CFC"), i.e.,foreign corporations where more than 50 of the stock of the foreign corporation is owned, directly or indirectly, by U.S. shareholders, are required to currently report in taxable income their share of the CFC’s Subpart F income regardless of whether such income is distributed to the 10 or more shareholders

Eleventh Circuit affirms lower court's holding that consulting partner's sale of Ernst & Young interest was taxable in year of sale despite temporary limitations on economic enjoyment

Fox Rothschild LLP
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USA
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April 22 2011

In U.S. v. Fort, 107 AFTR 2d 2011-739 (11th Cir. 4192011) a three-judge panel of the Eleventh Circuit upheld a federal district court's (Northern District of Georgia) decision, granting the Department of Justice, Civil Tax Division, summary judgment on that issue that under the constructive receipt doctrine, a consulting partner's sale of an interest in Ernst & Young was a fully taxable in the year the interest was sold to Cap Gemini in exchange for the stock

Financial Accounting Standards Board's oversight group will test a new review process for existing standards under FIN 48

Fox Rothschild LLP
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USA
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May 23 2011

The Financial Accounting Standards Board's oversight organization announced May 20 that it will test a new review process for existing standards with an analysis of FASB Interpretation No. 48, "Accounting for Uncertainty in Income Taxes."

New final and temporary regulations on treatment of certain intercompany gains with respect to stock owned by members of a consolidated group of corporations

Fox Rothschild LLP
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USA
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May 23 2011

On March 4, 2011, the Treasury issued T.D.9515, containing final regulations on the treatment of certain intercompany gains with respect to stock owned by members of a consolidated group

Recent decision of judgment of the Court (Grand Chamber) of EU in Akzo Nobel Chemicals, et al v. European Commission imperils attorney client privilege for foreign based subsidiaries, including in U.S. tax proceedings and non-tax proceedings

Fox Rothschild LLP
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European Union, USA
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June 26 2011

In a decision that has wide-sweeping implications for companies that are doing business in the EU or otherwise become a party to a legal or administrative proceeding governed by the EU, as well as to American persons engaged, directly or indirectly such as through ownership of a controlled subsidiary or company in the EU, the Grand Chamber of the EU Court affirmed the decision of the Court of First Review (trial court) holding that various claims of legal privilege made by Akzo Nobel Chemicals and Akcros Chemicals for communications made to the companies' in-house companies were not privileged and thus were discoverable under by the European Commission

Court of Federal Claims renders interesting statute of limitations decision in Russian Recovery Fund Ltd

Fox Rothschild LLP
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USA
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November 28 2011

In Russian Recovery Fund, Ltd., 108 AFTR2d 2011-5494, the Court of Federal Claims ruled that the Internal Revenue Service may proceed with a collection action against a partner in a lower-tier partnership or “indirect partner” provided such partner’s return was filed within three years of the issuance of a final partnership administrative adjustment (FPAA) to the upper-tier partnership with respect to partnership level items that were adjusted

French Parliament recently enacts legislation for tax and disclosure obligations on trusts: France's version of FATCA

Fox Rothschild LLP
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USA
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March 20 2012

Legislation passed by the French Parliament in July 2011 imposes a new set of tax and disclosure obligations on trusts which have some connection to France

Financial Accounting Standards Board continues to review application of Fin 48 (ASC-70) to private companies

Fox Rothschild LLP
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USA
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November 25 2012

"FIN 48 clarifies the guidelines for accounting of uncertainty in income taxes on financial statements of enterprises per FASB Statement No. 109, Accounting for Income Taxes, and removes uncertain income tax positions from the guidance provided under FAS 5, Accounting for Contingencies."