Searching Content indexed under Tax Authorities by Carlton Fields ordered by Published Date Descending.
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Hillsborough County Voters Pass Transportation Surtax - What Happens Next?
More than 57 percent of Hillsborough County voters approved the imposition of a 1 percent sales tax designed to improve the County's transportation infrastructure and transit service.
United States
14 Nov 2018
Tax Court Rejects Captive Insurance Company Status Under 501(C)(15)
Petitioner, a captive insurer domiciled in Anguilla, applied to be a tax-exempt small insurance company under IRC section 501(c)(15), and filed returns on this basis, making an election under IRC section 953(d).
United States
22 Aug 2018
New Jersey Tax Court Finds That Companies For Which New Jersey Is The Home State Must Pay Taxes On All Premiums Paid To Captive Insurers For U.S. Based Risks.
A tax court judge in New Jersey has handed Johnson & Johnson (J&J), and likely other New Jersey-based businesses that operate captive insurers, a significant loss in an opinion interpreting...
United States
15 Aug 2018
Cost-Sharing Regulations Revived By Ninth Circuit
The Ninth Circuit Court of Appeals reversed the Tax Court in Altera Corp. in the latest chapter of the dispute over the validity of cost-sharing regulations.
United States
6 Aug 2018
Get Ready: IRS To End OVDP
Recently, I discussed the impact of so-called "soft letters" sent by the IRS to various groups of taxpayers with offshore asset disclosure compliance issues (see this generic example of an IRS soft letter).
United States
24 Apr 2018
A Day Of Reckoning For Recalcitrant Taxpayers?
Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009
United States
26 Jan 2018
How To Manage Foreign Trusts With U.S. Beneficiaries
Do you or did you have a wealthy relative from a different country? Did that relative make you a beneficiary of a non-U.S. trust? Lucky you. But beware that free wealth.
United States
23 Nov 2017
Mergers & Acquisitions
For better or worse, the economy has caused an increase in the consolidation of tax exempt organizations as less robust organizations have sought refuge for their programs in larger, ...
United States
18 Oct 2017
Intellectual Property
Tax exempt organizations often overlook their ownership and use of intellectual property, particularly their trademarks and copyrightable materials.
United States
9 Oct 2017
Catching Up On The Changing Landscape Regarding "Micro" Captive Insurance Companies And The IRS's Strategy For Curbing Perceived
Starting with the 2015 iteration of its annual "Dirty Dozen" list, the IRS began an unprecedented crack down on suspected tax shelters using captive insurance companies.
United States
4 Jul 2017
Developing A Strategy To Fight FBAR Penalties
Since 2009, the number of FBAR penalties imposed for failures to report foreign bank accounts and the size of the penalties have both increased dramatically.
United States
8 May 2017
Tightening The Tax Screws On International IP Structures
This allows for low-taxed earnings to be accumulated and redeployed for further growth of the business.
United States
23 Mar 2017
IRS Treats Captives With Section 831(B) Elections As "Transactions Of Interest"
On the heels of Congress' amendments last year to Section 831(b) of the Internal Revenue Code to curb perceived abusive use of so-called "micro" captive insurance companies...
United States
19 Dec 2016
Tennessee Department Of Commerce And Insurance Issues Bulletin Advising Of Taxation Of Surplus Lines Premiums Post-NIMA Dissolution
In a special focus article in May, we wrote about the future of multi-state allocation of nonadmitted premium tax revenue following the dissolution of the Non-Admitted Insurance Multistate Agreement.
United States
10 Oct 2016
Surplus Lines Clearinghouse Provides Instructions Following The Dissolution Of The Non-Admitted Insurance Multistate Agreement (NIMA)
In a Special Focus article posted on May 2, 2016, we addressed the uncertain future of the multi-state allocation of non-admitted premium tax revenue.
United States
28 Jul 2016
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