In this month’s federal tax advisory, our Federal Tax Group explores how IRS Notice 2014-58 creates more confusion over the definition of “sham transaction doctrine.”
This advisory is provided on the Alston & Bird website: www.alston.com/advisories/economic-substance-doctrine/
What does Congress NEED to get done in a lame duck session? The continuing resolution (CR) Congress passed just before leaving for the campaign trail funds the federal government just through December 11, so Congress will need to extend funding. That’s clearly a driving force in the lame duck. There are also tax provisions that many would like to see addressed – the CR extended the Internet Tax Freedom Act just through December 11, and there are a whole host of business and individual tax provisions (including the very popular R&D credit) that expired at the end of 2013 or will expire [...]Read more
This advisory reviews the Multistate Tax Commission’s efforts to create an Arm’s-Length Adjustment Service program to streamline states’ ability to effectively evaluate multistate transfer-pricing issues.
This advisory is provided on the Alston & Bird website: http://www.alston.com/advisories/MTC-transfer-pricing/
Our International Tax Group explains how withholding agents must be especially vigilant in their reliance on foreign persons’ documentation of withholding certificates under new advice from the IRS.
This advisory is provided on the Alston & Bird website: http://www.alston.com/advisories/int-tax-10-15-14/
The Federal Tax Group explores factors in the revived interest in the C corporation, including the potential reduction in the corporate tax rate, reduced pressure to distribute earnings and cash flow savings.
This advisory is provided on the Alston & Bird website: http://www.alston.com/advisories/fed-tax-sept-2014/
Alston & Bird’s International Tax Group reviews congressional proposals to curb corporate inversions amid debate over the need for comprehensive tax reform. The advisory is provided on the Alston & Bird website: http://www.alston.com/advisories/int-tax-aug-2014/
During the current term, the Supreme Court of the United States decided very few taxes cases. Two of those—United States v. Clarke and Ford Motor Co. v. United States—seem quite limited in scope, until you delve under the surface.ine
This advisory is provided on the Alston & Bird website: www.alston.com/advisories/Fed-Tax-august-2014/
In an important decision with the potential to have long-lasting effects on Georgia property tax law, the Alston & Bird State & Local Tax (SALT) Team recently secured summary judgment for the Piedmont Park Conservancy (“the Conservancy”) in Fulton County Superior Court on the Conservancy’s claim that its charitable property is entitled to a “proportional” exemption from ad valorem tax.
This advisory is provided on the Alston & Bird website: www.alston.com/advisories/SALT-piedmont-park-conservancy/ [...]Read more
Following the administration budget’s proposal for stricter anti-inversion legislation, Congressmen Chris Van Hollen and Sander Levin have introduced the Stop Corporate Expatriation and Invest in America’s Infrastructure Act (H.R. 4679) to stiffen the provisions of Section 7874. (Senator Carl Levin introduced a similar proposal, S. 2360, in the Senate.) The proposed legislation epitomizes the government’s anti-inversion frenzy, as more U.S. companies look for greener tax pastures overseas.
This advisory is provided on the Alston & Bird website: www.alston.com/advisories/int-tax-july-2014/ [...]Read more
Rev. Proc. 2014-3 provides that the IRS won’t issue rulings on “the treatment or effects of hook equity, including as a result of its issuance, ownership, or redemption.” It defines hook equity as “an ownership interest in a business entity (such as stock in a corporation) that is held by another business entity in which at least 50 percent of the interests (by vote or value) in such latter entity are held directly or indirectly by the former entity.” But a recent ruling involved hook stock and predated the no-rule. LTR 201404002 involved a surprising but somewhat common [...]Read more