Federal Taxation

  • France Delays Implementation of New Tax Withholding System for One Year

    By:
    Michael Jaffe, Christophe Flaicher, PhD, and Bertrand Hermant, PhD, LLM
    |
    Sep 1, 2017
    In our May 2017 article, we mentioned that the implementation of a current year “pay-as-you-earn” (PAYE) withholding tax fell during an election year—and that the new president could get cold feet when confronted with this major change to the tax collection process.
  • 'Placed in Service' Does Not Mean 'Open for Business'

    By:
    Dennis Zinkevich, CPA
    |
    Jul 1, 2017
    On Apr. 13, 2017, the IRS issued an official Action on Decision (“AoD”) regarding its defeat in Stine, LLC v. United States. Stine addressed whether a building can be considered to be “placed in service”—meaning it is substantially complete and in a state of readiness and availability to carry out its specified function—before it is “open for business” for purposes of depreciation and the special Gulf Opportunity Zone (“Go Zone”) bonus depreciation. 
  • The Federal Education Deduction and Credits

    By:
    Carnet A. Brown, CPA
    |
    Jul 1, 2017
    When it comes to credits and deductions, the primary concern of most taxpayers is the effect on their tax refunds or tax liabilities. How much will their tax refunds increase, and how much will their tax liabilities be reduced? 
  • Tax Court Rules the Extension of Variable Prepaid Forward Contracts Is Not a Taxable Event

    By:
    LD Sergi and Matthew Kaufman
    |
    Jul 1, 2017
    On Apr. 19, 2017, the United States Tax Court in Estate of Andrew J. McKelvey v. Commissioner held that the extension of certain variable prepaid forward contracts (“VPFC”) did not result in a sale or exchange of property under IRC section 1001 and that the open transaction treatment provided to VPFCs in Revenue Ruling 2003-7 continues until the transactions are closed through the future delivery of the stock underlying the VPFC, or the cash equivalent. 

  • The Appropriate Approach to Misappropriation: Responding to Fraud in Non-Profit Organizations

    By:
    Israel Tannenbaum, CPA
    |
    Jun 1, 2017
    Fraud can be one of the most devastating discoveries within an organization—and reports about defrauded organizations suffering significant losses due to employee corruption are rising. 
  • France: Changes to the Tax Collection System and Other Current Tax Developments

    By:
    Michael Jaffe, Christophe Flaicher, and Bertrand Hermant
    |
    May 1, 2017
    A long-awaited change to the French tax system is scheduled to go into effect throughout the next two years: the implementation of a current year “pay-as-you-earn” (PAYE) system. France has aspired to change the system since World War II, and it would be the last member of the Organisation for Economic Cooperation and Development (OECD) to implement the change. 
  • Energy Incentive Programs: Good for the Earth and the Bottom Line

    By:
    Bruce A. Johnson, MBA, CEM
    |
    Mar 1, 2017
    These days, people talk a lot about “going green.” Companies promote environmentally conscious programs and policies to win new customers, improve public image, and reduce costs. Indeed, energy incentive programs may confer tremendous tax savings. 
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