| 
Top Stories Second Circuit Again Concludes Preferred Investor Was Not A Partner
Practice: Tax | Blog | The Second Circuit Court of Appeals has again concluded that a preferred investor was not a partner for tax purposes, denying an allocation of taxable income to the tax-indifferent investor. In 2004, the District Court originally held that the investor was a partner and the second circuit reversed under the traditional Culbertson “totality-of-the-circumstances test”. However,... |
Proposed Regulations Issued for DC’s New Combined Reporting Rules
Practice: Tax | Blog | In the fall of 2011, the District of Columbia (DC) adopted a “combined reporting” regime that effectively shares the taxable income of a DC subsidiary to certain related non-DC corporations. Other states have adopted similar rules, although the specifics vary significantly per state on questions such as whether related non-DC corporations are removed from combined... |
Second Circuit Again Concludes Preferred Investor Was Not A Partner
Practice: Tax | Blog | The Second Circuit Court of Appeals has again concluded that a preferred investor was not a partner for tax purposes, denying an allocation of taxable income to the tax-indifferent investor. In 2004, the District Court originally held that the investor was a partner and the second circuit reversed under the traditional Culbertson “totality-of-the-circumstances test”. However,... |
Proposed Regulations Issued for DC’s New Combined Reporting Rules
Practice: Tax | Blog | In the fall of 2011, the District of Columbia (DC) adopted a “combined reporting” regime that effectively shares the taxable income of a DC subsidiary to certain related non-DC corporations. Other states have adopted similar rules, although the specifics vary significantly per state on questions such as whether related non-DC corporations are removed from combined... |
|
|
|