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Service and Treasury issue final regulations modifying the New Markets Tax Credit Program to promote further investment in non-real-estate businesses in low-income communities
- Fox Rothschild LLP
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- USA
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- February 19 2013
In T.D. 9600, which was issued last Fall, the Service issued final regulations modifying the new markets tax credit ("NMTC") program to promote
Glimpse of Obama Administration's changes in taxation of U.S. based multinationals
- Fox Rothschild LLP
- -
- USA
- -
- December 3 2009
The Obama Administration set forth certain changes it will seek to have Congress adopt next year or beginning in 2011 as part of the 2010 budget proposals in the area of international taxation, particularly with respect to U.S. based multinational companies
First Circuit Court of Appeals holds tax accrual workpapers and related documents used to prepare financial statements are not work product under the Hickman v. Taylor doctrine
- Fox Rothschild LLP
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- USA
- -
- February 28 2010
In a decision deserving of Supreme Court review, the en banc decision of the First Circuit Court of Appeal in Textron, 104 AFTR 2d 2009-5719, 08132009 , has vacated the district court's determination that a public corporation's tax accrual workpapers were protected from IRS summons by the work-product doctrine
The Organisation for Economic Co-operation and Development ("OECD") issues discussion draft on athletes and entertainers under OECD Model Treaty
- Fox Rothschild LLP
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- Global, USA
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- August 3 2010
The United States has entered into approximately 50 income tax treaties with various countries, including most of all the economically developed countries
Year end tax planning: setting past years' peformance bonuses: deductible business expense or disguised dividend?
- Fox Rothschild LLP
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- USA
- -
- December 28 2009
In Menard, Inc., 560 F3d 620 (7th Cir., 2009), rev'g TC Memo 2004-207 , the Seventh Circuit Court of Appeals reversed the Tax Court and found in favor of the taxpayer that a large 5 bonus arrangement payment was in fact paid for services rendered and was deductible in computing the corporation's taxable income for 1998, the year in issue
IRS notice 2010-41, 2010-22 IRB 715: regulations will be issued that will classify some domestic partnerships as foreign partnerships for applying the controlled foreign corporation rules.
- Fox Rothschild LLP
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- USA
- -
- June 6 2010
On May 14, 2010, the IRS and Treasury announced in Notice 2010-41, that they will issue regulations classifying certain domestic partnerships as foreign partnerships for the purpose of identifying the US shareholders of a CFC with respect to income inclusions (for Subpart F income) in accordance with 951(a
Tax Court holds foreign parent's fee for guarantying U.S. subsidiary's debt is foreign source service income
- Fox Rothschild LLP
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- USA
- -
- May 29 2010
In Container Corp, 134 TC No 5 , Tax Ct Rep (CCH) 58131, 2010 WL 571831 (2010), a case of first impression, the Tax Court, per the opinion of Justice Holmes, held that payments received by Vitro, S.A., a Mexican corporation, from its US subsidiary for the guarantee of the subsidiary's debt obligations was not income from sources within the U.S. under Section 861 , and, therefore, was not subject to withholding under Section 1442
Gross up payments made with respect to golden parachute payments under Section 280G
- Fox Rothschild LLP
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- USA
- -
- 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
Court of Claims strikes down Wells Fargo's silos tax shelters
- Fox Rothschild LLP
- -
- USA
- -
- January 20 2010
Tax refund suit filed by WF claiming over $115M in depreciation, interest and expenses for 2002 in connection with participating in 26 leveraged lease transactions, 17 with domestic transit agencies and 9 pertaining to qualified technological equipment ("QTE"
IRS issues action on decision and nonacquiescence to the Fifth Circuit Court of Appeals recent decision in Tidewater, Inc. and subsidiaries
- Fox Rothschild LLP
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- USA
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- August 3 2010
In Tidewater, Inc and Subsidiaries v US, 565 F3d 299 (4132009), the Fifth Circuit affirmed the District Court's determination in a tax refund suit, reported at 100 AFTR2d 2007-6360 (DC LA 2007), which granted controlled groupoceangoing vessel owner-operators' refund of an overpayment of tax attributable to its claim that it could deduct, under the former foreign sales corporation provision, commissions paid to a foreign sales corporation on the portion of income allocated to the leasing component of time chartersmixed lease-service agreements
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- Workarea - Corporate Tax
- Author - Jerald David August
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