Ultimate parents of U.S. multinational enterprises now have instructions for Form 8975, the U.S. Country-by-Country Report. Our International Tax Group reviews what U.S. MNEs must do to comply with new U.S. filings requirements, as well as procedures for voluntary early filing intended to satisfy BEPS-related Organisation for Economic Co-operation and Development guidance in other jurisdictions.
Fixing the reporting mismatch
Revenue Procedure 2017-23
The form and instructions
Read the full International Tax Advisory here. [...]Read more
On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some alterations, these regulations deliver on guidance announced in Notice 2015-54, released in August 2015 (see our prior coverage of Notice 2015-54 here). The regulations incorporate a number of taxpayer-friendly updates in response to comments on the Notice. The prospect of further direction in this area, however, including guidance under Sections 482 and 6662 as described in the [...]Read more
Now that Delaware's rewrite of its escheats laws is enshrined in Delaware law, holders will soon be faced with making some important decisions about audits and the VDA program. Our Unclaimed Property Group takes stock of what it means for holders going forward.
Read the full advisory here. [...]Read more
There are still many questions about the meaning of the Treasury’s new regulations applying Section 355(e) to predecessors and successors. Our Federal Tax Group examines the answers we do have and what they mean for practitioners.
Exactly two weeks after introduction, Delaware’s major unclaimed property overhaul bill – SB 13 – passed both the Senate and the House of Delaware’s General Assembly on January 26. The bill is now on the desk of newly inaugurated Governor Carney and is awaiting signature. We have previously addressed some of the significant features of SB 13 here. To summarize, SB 13 represents a complete rewrite of the Delaware Escheats Law in reaction to the Temple-Inland decision and other recent unclaimed property developments. Although SB 13 is inspired by and based in part on the new 2016 [...]Read more
In December, we wrote about a new gift card law in New York that took effect on Christmas day (http://www.alston.com/advisories/ny-gift-card-legislation/), which was enacted by Senate Bill S. 4771-E. Under that now-effective law:
Gift card issuers are prohibited from charging a service fee before the twenty-fifth month of dormancy, and any service fees that are applied after this time must be waived and put back on the card if the card is used within three years of the issue date.
No gift card may have an expiration date of earlier than five years from the date the card was issued or the [...]Read more