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Although Oregon’s 2021 legislative session turned out to be relatively quiet from a tax perspective, we did experience some changes to Oregon’s Corporate Activity Tax (“CAT”). Those changes were primarily in the form of SB 164. The enactment of SB 164 ushers in the following CAT changes. Fiscal Year Filings ...

Shearn Delamore & Co. | September 2020

Income tax The following public rulings and guidelines have recently been published on the Inland Revenue Board of Malaysia’s official website: i. Tax Treatment of Research and Development Expenditure Part I – Qualifying Research and Development Activity (Public Ruling No. 5/2020) issued on 13 August 2020; ii. Tax Treatment of Research and Development Expenditure Part II – Special Deductions (Public Ruling No. 6/2020) issued on 13 August 2020; iii ...

ALTIUS/Tiberghien | March 2024

In an earlier article in this series, we already discussed the planned changes in terms of moveable income. Whilst the changes may seem relatively limited at first glance, Dutch residents immigrating to Belgium will however encounter several peculiarities as set out in this article. Capital gains   Capital gains, i.e. on shares, are in principle taxable in the state of residence ...

Waller | February 2019

The Tax Cuts and Jobs Act of 2017 (the “TCJA”) created a new tax incentive designed to encourage long-term investment in low income communities, as defined in Code Sec. 45D(e),1 which are specifically designated as “qualified opportunity zones” (“QOZs”) in accordance with procedures set forth in Code Sec. 1400Z-1 ...

Waller | June 2016

A large percentage of closely held businesses restrict or even prohibit the owners’ ability to transfer their equity interests. Often these restrictions require the owner to sell the equity back to the entity or the other owners at a formula value, for example, book value, that is not anticipated to be a true fair market value. These and other permanent restrictions on equity interests are called nonlapse restrictions because by their terms they never go away or “lapse ...

Waller | August 2016

Generally when a successful business is acquired, whether by an asset acquisition or an equity acquisition, the assets will includeboth tangible and intangible property. When an entity conducting a business is liquidated, the tangible and intangible assets of the entity are distributed to the owners. Often, one very valuable intangible that does not appear on the balance sheet is goodwill ...

Waller | October 2016

The Series Limited Liability Company (“Series LLC”), a variation of the traditional limited liability company (LLC), is the newest entity enterprise on the business scene today.1 Within this legal entity, separate “series” or “cells” can be created and established under the umbrella of a single LLC ...

Waller | March 2017

Although its emergence on the business scene is fairly recent, the Series LLC has been gaining popularity as a business entity. Under the Series LLC umbrella, this entity is able to create multiple Protected Series, each with its own separate rights, powers, assets, obligations, business purposes and associated members ...

Waller | May 2016

Vodafone Variance: The Commissioner's Power to Override the Rules Following the Tennessee Court of Appeals decision in Vodafone Americas Holdings, Inc ...

During the height of the #MeToo movement and in the wake of the Harvey Weinstein scandal, Congress enacted a sweeping tax reform bill containing a provision intended to penalize businesses who settle claims involving sexual harassment or sexual abuse if they include nondisclosure agreements as part of a settlement. As with many rushed pieces of legislation, legal commentators have more questions than answers about the practical effect of this tax amendment ...

Haynes and Boone, LLP | November 2010

In response to the current state of the economy, Congress has passed some tax legislation amending the Internal Revenue Code (the “Code”). Although it is up for debate, some would say that Congress has not been busy enough. As we near the end of the year, many taxpayers and their advisers are going through their usual year-end tax planning checklist ...

DFDL | September 2021

Another wave of COVID-19 has spread all over Thailand and is raising understandable concerns and generating uncertainty among the business community. With this series of infographics, we take this opportunity to guide you on the key measures and best practices to help you mitigate the effects of the COVID-19 pandemic on your business. Today, we guide you through the debt restructuring options available in Thailand for local or foreign investors ...

DFDL | September 2021

Another wave of COVID-19 has spread all over Thailand and is raising understandable concerns and generating uncertainty among the business community. With this series of infographics, we take this opportunity to guide you on the key measures and best practices to help you mitigate the effects of the COVID-19 pandemic on your business ...

Haynes and Boone, LLP | December 2011

Following is a list of year-end administrative issues for Texas limited partnerships and limited liability companies (“LP/LLC”): Ensure that the LP/LLC’s activities, transactions, capital infusions (capital contributions or loan proceeds), and distributions are accurately reflected in the entity’s records; Avoid causing the LP/LLC to make any distributions not in compliance with the terms of its LP/LLC agreement or applicable law; for example, an LP/LLC should not make disproportiona

ENSafrica | October 2017

The 2014 changes to the South African Mineral and Petroleum Resources Royalty Act, 2008 (the “Royalty Act”) have left mining companies and extractors (“taxpayers”) in uncertain territory ...

Haynes and Boone, LLP | November 2010

First, the good news: No estate tax on individuals who die during 2010; No generation-skipping transfer (“GST”) tax on “transfers” during 2010; Tax rate on gifts during 2010 is 35% (rather than 45%); and Congress appears less likely to take any action to retroactively change these rules ...

PLMJ | February 2010

In light of the ineffectiveness of tax litigation and the increased mistrust of taxpayers in relation to tax decisions, with the decision-makers very often hiding behind mere decisions of form, it is imperative that we weigh up alternative methods for resolving tax disputes, such as mediation, conciliation, and tax arbitration itself, in order to deal with disputes accumulated and arising out of relations between the State and the taxpayer, thus reversing the fe

DSL Lawyers | February 2016

Besides other exemptions contemplated under the law that approved the 2016 budget for Macau SAR (Law No. 15/2015, of 28 December 2015), the core special exemptions applicable cover Corporate Tax, Professional Tax and Property Tax. Corporate Tax The taxable profits accrued in the companies’ annual accounts re ...

Hanson Bridgett LLP | October 2019

Governor Newsom has signed several bills that impact the cannabis industry by providing relief from federal income tax deduction limitations, encouraging minority participation, encouraging union membership, and clarifying some other existing regulations. The bills include: Assembly Bill 37 repeals the limitation on deductions for business expenses for cannabis businesses, which had previously conformed to Internal Revenue Code section 280E for state tax purposes ...

Buchalter | November 2020

The 2020 election in California as pertains to national politics was never in doubt, but despite being a deeply blue state, Californians continued to show their divide on taxing businesses and making major changes to the statewide tax code. Several ballot initiatives, both at the state and municipal level, would have radically altered how businesses and executives are taxed ...

ENSafrica | February 2020

In a slightly surprising, but nevertheless welcome, South African 2020 Budget Speech today, the Honourable Minister of Finance announced that there would be no significant tax increases to the major taxes for the forthcoming tax year. Widely anticipated increases to value-added tax (“VAT”), income tax, capital gains tax and estate duty did not materialise ...

Dykema | February 2021

The 2021 tax assessment of real and personal property will be determined by local Assessors in February, at which time a Notice of Assessment will be issued and mailed to property owners. Property owners should make sure to check the mail for a copy of the Notice in order to determine whether an appeal of their taxable value should be filed ...

Dykema | June 2021

On Friday, May 30, 2021, the U.S. Department of Treasury released its “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals” (the “Green Book”). The Green Book, a copy of which is locatedhere, provides detailed descriptions of the Biden Administration’s legislative tax proposals, which the White House formally announced on May 28, 2021, when it released its fiscal year 2022 Budget proposals ...

Dykema | April 2022

The 2022 tax assessment of real and personal property have been determined by the local Assessor and a Notice of Assessment was issued and mailed to property owners. Property owners should make sure to check the mail for a copy of the Notice in order to determine whether an appeal of their taxable value should be filed ...

On November 17, 2023, New York State Governor Kathy Hochul signed into law Senate Bill 4516, amending General Obligation Law Section 5-336 (GOL 5-336). As set forth in our earlier alert from when the law was first enacted, Section 5-336 limited employers’ use of nondisclosure provisions in agreements releasing claims involving sexual harassment ...

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