A case decided late last year, In the Matter of John Gaied v. New York State Tax Appeals Tribunal, has fanned the flames surrounding the Department's interpretation and application of the "permanent place of abode" rules of statutory residency. (957 N.Y.S.2d. 480 (App. Div. 2012))

On August 27, 2012, in Historic Boardwalk Hall LLC v. Comm'r, 694 F.3d 425 (2012), the United States Court of Appeals for the Third Circuit sided with the IRS and denied historic rehabilitation credits for a state authority's purported partnership with a credit investor, Pitney Bowes Inc...

The Marketplace Fairness Act of 2013 (MFA) has received a lot of media coverage since passing in the Senate with bipartisan support in early May.

Over the past few decades, the United States has entered into numerous bilateral income tax conventions with foreign governments. A primary purpose of these conventions is to ease the burden of double taxation on individuals and companies resident in each of the contracting states.

Intellectual property (often abbreviated as IP) covers patent, copyright, trademark, and other forms of technical or proprietary information, know-how and trade secrets. IP is increasingly becoming a valuable business asset. IP disputes are also becoming more common and carrying higher stakes. The well-publicized litigation between Apple and Samsung about the designs of smartphones and tablets is just one recent example of a headline-grabbing IP dispute between companies.

As Alvarez & Marsal Taxand heads into its 10th anniversary year, I want to personally extend my deepest thanks for allowing us to help guide you, our valued clients, through your most complex tax challenges.

On March 19, 2013, the Department of Treasury and IRS issued final regulations under Section 367(a)(5) concerning transfers of property by a domestic corporation to a foreign corporation in an exchange described in Section 361. The regulations replace proposed regulations issued in 2008 and, in large part, adopt the proposed regulations. In response to taxpayer comments, certain modifications were made to clarify the application of Section 367(a)(5). However, other proposed amendments intended to clarify and streamline the regulations were not adopted, leaving a few traps for the unwary. A few of the taxpayer friendly and not-so-friendly updates are discussed here.

Emboldened by their fellow states, the latest trend for states attempting to generate more tax revenue seems to be new legislative proposals adding affiliate and click-through nexus rules.

The IRS recently issued finalized Treasury Regulation 1.761-3 on the tax treatment of noncompensatory options issued by partnerships in circumstances unrelated to the performance of services.