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Fox Rothschild LLP | USA | 14 Dec 2012

Alternative investments by retirement plans

In the current investment climate involving historically low interest rates and an uncertain stock market, we have been approached by clients, consultants and third party administrators with the same request: “Can a plan invest in non-traditional investments, such as real estate?”


Fox Rothschild LLP | USA | 19 Nov 2012

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

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.


Fox Rothschild LLP | USA | 4 Nov 2012

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

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.


Fox Rothschild LLP | USA | 26 Oct 2012

Florida Supreme Court extends homestead exemption to non-residents

A unanimous Florida Supreme Court has rebuffed an appeal by the Property Appraiser of the state's largest county to deny an ad valorem property tax exemption to foreign property owners.


Fox Rothschild LLP | USA, Italy | 1 Jul 2012

Chief Counsel's advisory 201212008 holds green card holders working for foreign government in the United States were not exempt from U.S. tax

In CCA 20122008, the Chief Counsel’s Office ruled that compensation earned by green card workers while working for the Italian government in the United States is not exempt from the federal income tax pursuant to an 1878 U.S.-Italy consular convention on the basis that greencard holders can not be consular offices, nor under the 1984 U.S.-Italy income tax convention if Italy has the primary right to tax the worker, since the U.S. provides for foreign tax credits.


Fox Rothschild LLP | USA | 31 May 2012

French tax law changes

Beginning January 1, 2012, French residents with worldwide assets between 1.3 million and 3.0 million Euros are subject to a wealth tax of 0.25, and 0.5 from 3.0 million Euros.


Fox Rothschild LLP | USA | 13 Apr 2012

Third Circuit reverses tax court and holds taxpayers received tax-exempt interest on deferred payments from the Pennsylvania Department of Transportation negotiated as part of an out-of-court settlement

The Third Circuit, in partially reversing the Tax Court, in DeNaples v. Commissioner, 109 AFTR 2d 2012-1419 in a three judge panel opinion filed on March 19, 2012, held that two couples were in receipt of tax-exempt interest income under 103 with respect to installment payments made under an out-of-court settlement agreement with the State of Pennsylvania that arose out of an eminent domain proceeding.


Fox Rothschild LLP | USA | 26 Jan 2012

$5.12 million gift giving window of opportunity: 11 months and counting!

In prior alerts, we informed you of short-term planning opportunities involving family gifting.


Fox Rothschild LLP | USA | 14 Nov 2011

The U.S. Chamber of Commerce joins the fight against preserving hard drives for all potential class action members

On November 7, 2011, the U.S. Chamber of Commerce (the “Chamber”) filed an amicus brief in support of the motion by KPMG LLP (“KPMG”) to set aside the Southern District of New York’s denial of its application for a protective order.


Fox Rothschild LLP | USA, Canada | 8 Nov 2011

New technical interpretation issued by Canada Revenue Agency on stock options will spark debate

A recent technical interpretation issued by the Canada Revenue Agency, Technical Interpretation 2011-0393411E5, provides that under Article XV of the Canada-U.S. Income Tax Convention, that after 2008, when a U.S. resident employee of a Canadian resident corporation acquires shares of the corporation on the exercise of employee stock options, the Canada Revenue Agency (CRA) would disallow that the income from the taxable amount would qualify for exemption from Canadian income tax under the Canada-U.S. Tax Treaty, even if the employer was not present in Canada for more than 183 days.

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