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Service issues final regulations (T.D. 9606) on sales of stock between controlled corporations: redesigning the anti-avoidance regulation in Section 304

Fox Rothschild LLP
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USA
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December 30 2012

Most tax practitioners are familiar with the redemption provisions under Section 302 which provide whether a selling shareholder must treat the

United States enters into third intergovernmental agreement under FATCA: agreement signed with Mexico

Fox Rothschild LLP
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Mexico, USA
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December 6 2012

On November 19, 2012, the Treasury announced that it had entered into a third intergovernmental agreement or “IGA” , this time with the country of Mexico pursuant to the Foreign Account Tax Compliance Act (FATCA

U.S. and multi-national companies engaged in Canadian business operations through controlled Canadian subsidiaries need to stand on guard for possible legislation on interest stripping and other rules

Fox Rothschild LLP
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Canada, USA
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December 6 2012

Many U.S. companies engage in business operations in foreign countries, including Canada, through the use of a controlled or wholly owned subsidiary

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."

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

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

Treasury Department announces further actions to implement the Foreign Account Tax Compliance Act (FATCA)

Fox Rothschild LLP
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USA
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November 19 2012

FATCA was enacted in 2010 by Congress as part of the Hiring Incentives to Restore Employment (HIRE) Act

Department of Justice, Civil Tax Division, awarded summary judgment to collect civil penalties against taxpayer for willfully failing to FBAR reports for two years

Fox Rothschild LLP
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USA
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November 19 2012

The United States District Court for the District of Utah, Central Division, on November 8, 2012, Judge Nuffer, granted the United States its motion for summary judgment for the taxpayer-defendant’s, Jon Mc Bride, willful failure to report his interest in foreign bank accounts in contravention of 31 U.S.C. Section 5314 for the years 2001 and 2002

Service issues first notices on Hurricane Sandy; casualty losses, government assistance payments

Fox Rothschild LLP
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USA
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November 4 2012

Late on Friday, November 2, the IRS announced that in addition to declaring Hurricane Sandy a Federal Disaster it also stated that the storm was a “qualified disaster for purposes of Section 139” and that qualified disaster relief payments made to individuals by their employer or any person can be excluded from those individuals’ taxable income

Transfer pricing decision recently rendered by the Supreme Court of Canada in GlaxoSmithKline, Inc. v. The Queen, 2012 SCC 52

Fox Rothschild LLP
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Canada
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November 4 2012

Last month the Supreme Court of Canada (SCC) rendered a unanimious decision in GlaxoSmith Kline, supra

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Search results

Service issues final regulations (T.D. 9606) on sales of stock between controlled corporations: redesigning the anti-avoidance regulation in Section 304

United States enters into third intergovernmental agreement under FATCA: agreement signed with Mexico

U.S. and multi-national companies engaged in Canadian business operations through controlled Canadian subsidiaries need to stand on guard for possible legislation on interest stripping and other rules

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

Capital gains and dividend income tax rates scheduled to increase in 2013: added impact of new Medicare contribution tax

Capital gains and dividend income tax rates scheduled to increase in 2013: Added Impact of New Medicare Contribution Tax

Treasury Department announces further actions to implement the Foreign Account Tax Compliance Act (FATCA)

Department of Justice, Civil Tax Division, awarded summary judgment to collect civil penalties against taxpayer for willfully failing to FBAR reports for two years

Service issues first notices on Hurricane Sandy; casualty losses, government assistance payments

Transfer pricing decision recently rendered by the Supreme Court of Canada in GlaxoSmithKline, Inc. v. The Queen, 2012 SCC 52

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