The IRS’s long and tortuous repair regulation journey neared completion with the issuance of final repair regulations in T.D. 9636 on September 19, 2013, and Rev. Proc. 2014-16 (I.R.B. 2014- 7, January 24, 2014) detailing the accounting method changes needed to comply with the regulations. Unfortunately for taxpayers (and their return preparers), the journey to implement these rules has ... read more
On February 14, 2014, the Internal Revenue Service released the Transfer Pricing Audit Roadmap (the “Roadmap”), which provides an outline for the stages of a transfer pricing audit. The Roadmap is intended for use by international examiners involved in 24-month audits, and states that transfer pricing specialists should be involved ... read more
On February 11, 2014, Finance Minister Jim Flaherty tabled the 2014 federal budget. The government continues to show restraint, and with the Winter Olympics well underway, major tax changes were not expected. The focus of today’s budget was setting the final path to balancing the books.
BDO China has issued a Tax Newsletter that provides an update on PRC taxes up to February 2014. In this update, you will find news and tips from BDO China on: urban land use tax on barren hills, woodland, and lakes; new administrative measures on tax refund (exemption) for zero-rated ... read more
On January 15, 2014, in Graphic Packaging Corp. v. Combs, Cause No. D-1-GN-12-003038, the District Court of Travis County, Texas, 353rd Judicial District (the “District Court”), issued an order granting the Comptroller’s motion for summary judgment, and issued an order denying Graphic Packaging Corporation’s (“Graphic’s”) motion for summary judgment. The ... read more
Employers who reported severance pay as FICA wages on 2010 employment tax returns have until April 15, 2014, to file a protective claim for refund. This action will ensure the employer will not lose its ability to claim a FICA tax refund for 2010 before the Supreme Court decides the ... read more
A recent Tax Court decision, Crescent Holdings LLC v. Commissioner, 141 TC No. 15, Dec. 2, 2013, highlights several significant implications when a partnership issues equity compensation to service providers. This case emphasizes the substantially different tax consequences resulting from the issuance of capital interests compared with profits interests in ... read more
The following discussion provides a summary of your current obligations under the IRS and Pennsylvania payroll tax and information reporting rules, that we believe you may find helpful in the operation of your business. Please note that this summary is being provided for informational purposes, and is not intended to ... read more
On January 2, 2014, Michigan Gov. Rick Snyder signed into law Senate Bill 367,1 which allows a corporate taxpayer to make an irrevocable election to include all more-than-50-percent owned, non-unitary corporations, financial institutions, and insurance companies in a Corporate Income Tax combined return.
2013 was an eventful year for federal tax developments, notable from its onset by passage of the American Taxpayer Relief Act of 2012 (ATRA), which permanently extended the Bush-era tax cuts for all but higher-income taxpayers as well as numerous other important, but previously temporary, provisions. The year also saw an ample release of important guidance relating to ... read more