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Service prevails before Tax Court in self-employment tax case
- Fox Rothschild LLP
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- USA
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- January 21 2013
In a recent memorandum decision of the Tax Court in Howell, TCM 2012-303, a couple was held liable for a deficiency in self-employment taxes, plus
Capital gains and dividend income tax rates scheduled to increase in 2013: added impact of new Medicare contribution tax
- Fox Rothschild LLP
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- USA
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- November 19 2012
Unless Congress can act decisively before the end of this year, the marginal federal income tax rates will increase for taxable years beginning on or after January 1, 2013
Structuring compensation arrangements for US individuals working overseas
- Fox Rothschild LLP
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- USA
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- November 11 2010
A frequently raised issue in tax planning for U.S. companies engaged in business operations overseas is the proper employment type relationship that should be used for the business person who is going to be rendering services in one or more foreign jurisdictions
Anticipated up-tick in merger and acquisition activity; don't forget about the change of control provision, Section 280G
- Fox Rothschild LLP
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- USA
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- August 23 2010
Congress enacted 280G in 1984 over concern that contracts between a corporation and its employees providing golden parachutes directly (or indirectly) attributable to a takeover of a target company would have an adverse effect on takeover activity in general, elevate the concerns of the management of the target company beyond permitted boundaries, including the deflection of shareholder value from the target's shareholders to key management and control shareholders of the target company
Lebron James, the Miami Heat and Section 409A of the Internal Revenue Code
- Fox Rothschild LLP
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- USA
- -
- July 16 2010
After an hour long television special last Thursday night, the "Decision" was announced on national television
Gross up payments made with respect to golden parachute payments under Section 280G
- Fox Rothschild LLP
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- USA
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- May 30 2010
Section 280G provides, in general, that the service provider receiving an excess parachute payment must incur a 20 nondeductible excise tax on the excess portion of the parachute payment which is usually associated with a payment triggered by virtue of "change of control" provision in an executive employment agreement
Current Search
- Jurisdiction - USA
- Workarea - Corporate Tax
- Workarea - Employment & Labor
- Author - Jerald David August