United States

The Tax Exchange - August 2017

Avoid technicalities to meet administrative protest filing deadlines

Avoid technicalities to meet administrative protest filing deadlines

The most common mistake resulting in a state tax protest denial is submitting the filing outside the statutory deadline. Whether it is 15, 30, 45 or 90 days, depending on the state, a number of factors can impact a timely filing.

  • August 30, 2017
Issues to consider when multiple foreign subs guarantee the same loan

Issues to consider when multiple foreign subs guarantee the same loan

In some cases, a U.S. taxpayer may have multiple inclusions of income that exceed the total loan amount under an obscure technical tax rule.

  • August 29, 2017
Foreign financial institutions must update FATCA agreements by Oct. 24

Foreign financial institutions must update FATCA agreements by Oct. 24

The IRS has recently updated the Foreign Account Tax Compliance Act frequently asked questions webpage, giving foreign financial institutions otherwise in compliance with their FFI agreements until Oct. 24, 2017, to renew their agreements in order to continue to be treated as participating FFIs.

  • August 25, 2017
Ohio CAT situsing: avoiding the hot tin roof with recent guidance

Ohio CAT situsing: avoiding the hot tin roof with recent guidance

Recently, the Ohio Board of Tax Appeals issued a decision addressing the situsing of sales under the state’s Commercial Activity Tax (CAT). In Greenscapes Home and Garden Products, Inc. v. Testa, the board found that an “ultimate destination” test is the key inquiry in determining whether sales of tangible personal property should be sitused to the state.

  • August 07, 2017
Key differences between redemption and sale of partnership interests

Key differences between redemption and sale of partnership interests

There are substantial tax differences between a redemption (a partner is redeemed out by the partnership) and a sale of a partnership interest.

  • August 03, 2017
Republican health care reform efforts blocked in the Senate

Republican health care reform efforts blocked in the Senate

On July 28, 2017, the Senate voted against a Republican health care bill known as the Health Care Freedom Act. The Health Care Freedom Act was the Republican’s latest draft of legislation to modify the Affordable Care Act (ACA).

  • August 01, 2017