On July 18, 2016, the Treasury Department published final regulations on non-issue price arbitrage restrictions (the “Final Regulations”) in the Federal Register.
A bill that would exempt aircraft management fees from the federal air transportation excise tax is advancing in the House — good news for aircraft owners who use a leasing company structure to save on state sales tax when purchasing aircraft.
Taxpayers value confidentiality, particularly if there is a dispute with the IRS that involves highly-sensitive trade secrets or other confidential information.
Privately-Owned Marinas Are Not Exempt from Ad Valorem Taxation in Florida, but What About City-Owned Marinas?
In City of Fort Pierce v. Treasure Coast Marina, LC, No. 4D14-3064, 2016 WL 3087680 (Fla. 4th DCA May 31, 2016), the Fourth District Court of Appeal addressed whether a marina that was owned and operated by a municipality should qualify as a traditionally exempt “municipal or public purpose” for ad valorem tax exemption purposes under Article VII, Section 3(a) of the Florida Constitution.
On July 13, 14, and 15, 2016, Judge Laro of the US Tax Court (Tax Court) ruled on five taxpayer-filed motions in limine to exclude expert reports in Guidant LLC f.k.a. Guidant Corporation, and Subsidiaries, et al. v. Commissioner.
IRS Issues Safe Harbors Under Which the IRS Will Not Assert That a Corporation Lacks the Requisite ‘Control’ for Purposes of Section 355(a)
On July 15, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-40.
In general, proposed rulemaking issued in December 2008 with respect to income inclusion under Section 409A of the Internal Revenue Code of 1986, as amended (available here) provides that if there is a Section 409A violation in a taxable year, all compensation deferred under the applicable nonqualified deferred compensation arrangement for that taxable year and all preceding years is includible in the service provider’s gross income to the extent not subject to a substantial risk of forfeiture (i.e., vested) and not previously included in gross income in a prior taxable year.
On July 13, 2016, Judge Buch of the US Tax Court denied an Internal Revenue Service (IRS) motion to compel the production of electronically stored information (ESI) by Dynamo Holdings Limited Partnership and Beekman Vista, Inc., which was not delivered as part of a discovery response based on the mutually agreed-upon use of “predictive coding.”
Preferring words over numbers, I chose the practice of law.