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Proxy agreement no barrier to affiliated group membership
- Morrison & Foerster LLP
- -
- USA
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- April 30 2013
In a recent private letter ruling, the IRS addressed whether a wholly-owned subsidiary could be included in its parent's affiliated group, even
No exemption where independent contractors both deliver products and solicit sales
- Morrison & Foerster LLP
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- USA
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- April 4 2013
A recent Advisory Opinion holds that an out-of-state company is not eligible for the Article 9-A fulfillment services exemption, or the protections
Business income in California and legal ruling 2012-01
- Morrison & Foerster LLP
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- USA
- -
- November 5 2012
A recent State Local Tax Insights article discussed “Potential Unity and Business Income in California.”
Tax Court recharacterizes preferred equity as debt in Hewlett-Packard case
- Morrison & Foerster LLP
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- USA
- -
- July 9 2012
In Hewlett-Packard Co. v. Commissioner, the Tax Court recharacterized preferred equity owned by Hewlett-Packard Co. (“HP”) in a Dutch corporation as indebtedness and denied HP foreign tax credits and a capital loss on the exit transaction
Failure to establish value of assets in a bulk sale leads to liability for entire sales tax deficiency
- Morrison & Foerster LLP
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- USA
- -
- July 2 2012
Upholding the decision of an Administrative Law Judge, the New York State Tax Appeals Tribunal held that the transfer of business assets from a son’s company to his mother’s company constituted a transfer in bulk under Tax Law 1141(c), and that the mother’s company was liable for the full amount of sales tax due by failing to establish the fair market value of the assets transferred
IRS releases field attorney advice disallowing benefits of a dividends-received deduction transaction
- Morrison & Foerster LLP
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- USA
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- April 30 2012
In our last issue of Tax Talk, we highlighted a Chief Counsel Advice Memorandum in which the IRS argued that cumulative preferred stock was Section 1504(a)(4) preferred stock because a payment of unpaid accumulated dividends upon redemption at maturity was not an “unreasonable redemption premium.”
Empire zone tax benefits not lost by restructuring of taxpayer entity
- Morrison & Foerster LLP
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- USA
- -
- March 1 2012
The Department of Taxation and Finance has ruled that an LLC treated as a partnership for income tax purposes that was certified for New York State Empire Zone (“EZ”) tax benefits did not lose its certification as a result of its inserting two new singlemember LLCs as direct owners, where the two original members retained the same indirect ownership and control of the LLC after the restructuring
IRS technical advice: cumulative preferred stock that pays accumulated dividends at redemption is Section 1504(a)(4) preferred stock
- Morrison & Foerster LLP
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- USA
- -
- February 2 2012
A corporate taxpayer is generally entitled to a 70 percent dividends-received deduction with respect to dividends received from a domestic corporation
Managing withholding for a mobile workforce: special treatment of deferred compensation and stock options
- Morrison & Foerster LLP
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- USA
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- January 17 2012
Tax managers and payroll administrators in companies with employees traveling to many states on business face a formidable burden in learning and complying with difficult withholding requirements in various states
Update on partial relief from responsible person liability for limited partners and LLC members
- Morrison & Foerster LLP
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- USA
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- October 4 2011
In the May 2011 issue of New York Tax Insights, we discussed a new policy memorandum of the Department of Taxation and Finance that provided partial relief from personal liability from sales tax for qualifying limited partners and members of limited liability companies
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- Workarea - Corporate Tax
- Workarea - Company & Commercial
- Firm Name - Morrison & Foerster LLP
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