THE SPLIT DOLLARMINATOR!
Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more
Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more
On July 28, 2022, the Alabama Tax Tribunal held that a corporation is not required to add back interest paid to a related entity as the recipient was subject to tax on that income in Ireland. This was so even though the...more
On September 6, 2019, the Internal Revenue Service (IRS) announced the new “Relief Procedures for Certain Former Citizens” (IRS Relief Procedures) who relinquished their United States (U.S.) Citizenship after March 18, 2010....more
Backup Withholding requires a payer to “withhold tax” from payments that are not otherwise subject to withholding. A Taxpayer (payee) may be subject to Backup Withholding if it...more
As previously announced, the Illinois Department of Revenue has begun a new amnesty program, running October 1 through November 15, 2019. All taxes paid to the Illinois Department of Revenue for taxable periods ending after...more
South Carolina imposes a number of civil tax penalties that are similar to those imposed under the Internal Revenue Code (the “Code”). South Carolina’s civil tax penalties, while similar in some respects, are not the same as...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
The Tax Cuts and Jobs Act of 2017 (“TCJA”) made substantial changes to the Tax Code of 1986 by reducing tax rates and “simplifying” tax compliance for many by significantly increasing the standard deduction and eliminating...more
New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can consider placing the account into “currently not collectible” (CNC) status. If placed in CNC status, a...more
The South Carolina General Assembly approved a law in 2015 allowing the South Carolina Department of Revenue to offer an amnesty program to taxpayers in the state who have not filed tax returns and/or owe state taxes....more
The State of Arizona’s 2016 amnesty program offers significant benefits to most individuals and corporations with past-due taxes. Once again, Arizona taxpayers with many types of past-due state and local taxes will have...more
The Alabama Department of Revenue has just finalized its new local nexus regulation, Ala. Admin. Code Rule 810-6-5-.04.02, that will apply to transactions occurring on or after January 1, 2014, following its rule-making...more