Income Tax

Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

February 17, 2021 By Brian Harvel and April McLeod

Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes. What is the new jurisdictional nexus requirement?Why is Treasury worried about Europe’s digital services taxes?What are the arguments against the new nexus requirement? Read the full advisory here. [...]Read more

IRS Ruling on IRAs Raises Numerous Unclaimed Property Issues for Holders, Owners, and States Alike

June 5, 2018 By Kendall Houghton, Michael Giovannini and Kathleen Cornett

Many states have begun to treat IRAs as unclaimed property even before the owner can take a tax-free distribution. But now the IRS has ruled that escheatment is equivalent to a distribution and subject to federal income tax withholding and reporting requirements. Our Unclaimed Property Group dives into this dilemma for holders, owners, and states alike.

Revenue Ruling 2018-17 concludes that escheatment of an IRA is a designated distribution
Holders must honor federal tax withholding and reporting rules upon escheat
States are aggressively auditing IRAs
Potential negative impact on [...]Read more

Unclaimed Property ADVISORY: Delaware Moves to Revamp Its Unclaimed Property Law

January 17, 2017 By Michael Giovannini and Kendall Houghton

Our Unclaimed Property Group explores legislation introduced in the state Senate that if enacted, would prompt a sea change in Delaware law governing abandoned and unclaimed property.

Read the full advisory here.