The Tax Exchange
Tax discussions for the business leader
As we move past the tax filing deadlines and towards year-end planning, taxpayers should be aware of several important international tax considerations. Here are some of the key issues you may wish to consider.
Businesses normally know when they have created a split dollar life insurance arrangement. However, sometimes these arrangements happen accidentally.
A month ago the European Commission (EC) announced that Apple Inc. would have to pay Ireland over $14.5 billion, plus interest, for having received what the EC now considers illegal tax benefits over the past decade. The EC’s ruling instantly resulted in significant media coverage—largely due to the size of the back taxes owed.
Businesses across the country, and no doubt around the world, are watching the upcoming U.S. election very closely. Despite the personal attacks and rhetoric, there are major economic issues that may be impacted by the results.
In recent years, there has been quite a lot of discussion among retailers and state and federal governments over state revenue losses stemming from e-commerce and remote sales. Some states have taken legislative and regulatory approaches to enhance use tax collection, encourage voluntary sales tax collection and remittance by remote sellers, and directly challenge the physical presence standard adopted in Quill v. North Dakota.
Many M&A transactions include provisions for breakup fees payable if a party to the transaction backs out of the deal. Many taxpayers generally view a breakup fee as an ordinary expense deductible by the payor. However, the IRS recently issued a Field Attorney Advice ruling that a breakup fee generated a capital loss.