Miller, Canfield, Paddock and Stone PLC 14 July 2022 Miller, Canfield, Paddock and Stone PLC To print this article, all you need is to be registered or login on Mondaq.com. Key Takeaways: Of Boechler PC, v. commissionerone(“boechler“), the Supreme Court held that the thirty-day period to petition the Tax Court…
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Tax planning is often a vital consideration in an exit strategy for business owners. While most business advisors factor in federal income tax consequences when analyzing transaction structures, state income tax consequences seldom take center stage. Nevertheless, state income taxes can pose a significant tax burden for business owners upon exit and should be analyzed…
To print this article, all you need is to be registered or login on Mondaq.com. The High Court case of Commissioner of Taxation v Carter [2022] HCA 10 confirmed that the right to trust income is decided by the Trustee on or before 30 June of any year and any retrospective disclaiming is of no…
This article was published in Thomson Reuters Weekly Tax Bulletin on 8 July 2022. The NCAT Appeal Panel decision in Thomas and Naaz Pty Ltd v Chief Commissioner of State Revenue [2022] NSWCATAP 220 (Thomas and Naaz) released on 6 July 2022, has sounded warning bells for general medical practices. The appeal was dismissed reaffirming…
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To print this article, all you need is to be registered or login on Mondaq.com. Barrington v. commissioner, TC Memo. 2022-68 | July 6, 2022 | Buch, J.| mint. no. 1781-14 Opinion Summary: From October 2001 to July 2002, John Stewart Jakows served time in prison for a felony conviction for forgery and theft. After…
To print this article, all you need is to be registered or login on Mondaq.com. Buying a business is rarely a straightforward decision. In order to get the most out of a potential deal, buyers need to be aware of key risks and pitfalls so they can incorporate mitigation strategies into their deal negotiations. The…
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The bill contains several sections that complement and extend the existing domestic rules on tax transparency and exchange of information. On 13 June 2022, the Luxembourg government laid bill no. 8029 (the “Bill“) before Parliament. It would implement into domestic law Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation…
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On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile dealer leases. The dispute had arisen when the Canada Revenue Agency (“CRA”) disallowed CFI’s ITC claims because it…
Introduction to Roth IRA A Roth Individual Retirement Arrangement (“Roth IRA”) is an individual retirement plan available in the United States. Similar to a Canadian tax-free savings account (TFSA), for US income tax purposes, contributions made to a Roth IRA are not deductible from income but gains and earnings are income tax exempt. There are…
To print this article, all you need is to be registered or login on Mondaq.com. The US Tax Court’s June 23, 2022, decision in Morgan v. commissionerone addressing whether a taxpayer had a tax home in Saudi Arabia didn’t directly consider whether an individual was a bona fide resident of Puerto Rico, but it hit…
