The Economic Substance Doctrine: Coming To A State Near You?

By Jonathan Prokup Pennsylvania may soon join the other states that have challenged the use of the so-called Delaware Loophole, according to our colleagues at the State and Local Tax Blawg.  The legislation, contained in Pa. House Bill 2150, would disallow deductions that a parent operating corporation claims for royalty payments made to a "Delaware … Continue reading The Economic Substance Doctrine: Coming To A State Near You?

Tax Talk Around The Web

By Jonathan Prokup Business Spectator: Stalled R&D legislation stunts innovation (Australia).  As we discussed previously, temporary legislation makes for lousy tax policy, a problem that Australia seems to be experiencing right now. Forbes - Business in the Beltway: Taxes? Hold ‘Em!.  It seems that the pending deal on individual taxes will include a one-year extension … Continue reading Tax Talk Around The Web

International Tax Changes Take Flight

The House of Representatives passed, and the President signed into law, H.R. 1586, the "FAA Air Transportation Modernization and Safety Improvement Act," which curiously became the chosen vehicle for Congress and the Administration to provide assistance to states with budget shortfalls while paying for that assistance with changes in a number of international tax provisions.  … Continue reading International Tax Changes Take Flight

Certain Uncertainty: Congress Juggles Tax Proposals

By Jonathan Prokup Although death and taxes might, according to Benjamin Franklin, be the only certainties in this world, Congress is surely striving to add another - that is, the certainty of uncertainty.  Congress, it seems, is committed to keeping taxpayers in as much doubt as possible for as long as possible about the status … Continue reading Certain Uncertainty: Congress Juggles Tax Proposals

The Extenders Bill Is Dead. Long Live The Extenders?

By Jonathan Prokup Now that the tax extenders legislation has died, what’s next?  At least some of the provisions (e.g., the new tax regime for “carried interests”) are likely to find their way into future legislation.  But what about the tax extenders themselves, such as the look-through rule of section 954(c)(6) and the section 41 … Continue reading The Extenders Bill Is Dead. Long Live The Extenders?

Say That Again: A Summary of AJACTLA

By David Shakow If you haven’t memorized the 433 pages of the latest version of the American Jobs and Closing Tax Loopholes Act of 2010 (undoubtedly named to allow for the euphonious acronym, AJACTLA), you are denying yourself a unique treat.  (To get the true flavor, don’t forget the fifteen pages of amendments included with … Continue reading Say That Again: A Summary of AJACTLA

More on Wyden-Gregg’s Interest Disallowance Rule

By Jonathan Prokup and David Shakow You might recall our prior post on the Wyden-Gregg tax reform proposal in which we discussed the proposed limitation on corporate interest deductions.  To summarize, the legislation would limit the deductibility of payments on corporate debt to the amount of the interest in excess of the annual rate of … Continue reading More on Wyden-Gregg’s Interest Disallowance Rule