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156 results found


Fox Rothschild LLP | USA | 19 Feb 2013

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

In T.D. 9600, which was issued last Fall, the Service issued final regulations modifying the new markets tax credit ("NMTC") program to promote


Fox Rothschild LLP | USA, Japan | 12 Feb 2013

United States and Japan sign new protocol to amend the Japan-U.S. income tax treaty

As reported by the tax press and news release by the Treasury, Japan's Ambassador to the United States, Kenichiro Sasae and U.S. Treasury Deputy


Fox Rothschild LLP | USA | 5 Feb 2013

Treasury and Internal Revenue Service issues final and proposed regulations on the treatment of noncompensatory partnership options and convertible securities

Final regulations were issued (T.D. 9612) effective February 5, 2013 on the treatment of noncompensatory options and convertible instruments issued


Fox Rothschild LLP | USA, India | 2 Feb 2013

IRS Deputy Commissioner (international), large business and international division criticizes India's competent authority and tax administration features

The Convention and Protocol between the United States of America and the Republic of India signed on September 12, 1989 (“the Convention”)


Fox Rothschild LLP | USA | 28 Jan 2013

Treasury and service issue final regulations under the Foreign Account Tax Compliance Act

FATCA was enacted into law under the Hiring Incentives to Restore Employment Act of 2010 ("HIRE Act") which set forth, in new Chapter 4, Sections


Fox Rothschild LLP | USA | 21 Jan 2013

Service prevails before Tax Court in self-employment tax case

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


Fox Rothschild LLP | USA | 21 Jan 2013

Am I offering a taxable fringe benefit? Check the code

In the fiscal cliff debates last quarter, there was some discussion about limiting deductions or changing the Tax Code to eliminate certain


Fox Rothschild LLP | USA | 17 Jan 2013

Tax court finds shareholder's leasing of cell towers to S corporation was a passive activity despite corporation's grouping such leasing activities as part of the conduct of a trade or business

Petitioner-taxpayer leased land and telecommunication towers to his wholly owned S corporation, in exchange for a percentage of the Company's


Fox Rothschild LLP | USA | 13 Jan 2013

Application of Medicare contribution tax of 3.8 to certain U.S. persons owning stock in a controlled foreign corporation or passive foreign investment company

In REG-13050-11, the Service issued, on November 30, 2012, proposed regulations providing guidance under Section 1411 of the Internal Revenue Code


Fox Rothschild LLP | USA | 3 Jan 2013

Congress and President Obama sign into law the American Taxpayer Relief Act of 2012

On January 1, the Senate, by a vote of 89-8, passed H.R. 8, the "American Taxpayer Relief Act of 2012" ("ATRA"). ATRA was then rushed to the House of

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