- Three sets of regulations—final, temporary, and proposed regulations—concern the taxable income or loss of a taxpayer with respect to a “qualified business unit” (QBU) subject to section 987.
- Long awaited guidance takes the form of comprehensive proposed regulations interpreting the statutory rules, and temporary regulations that primarily incorporate guidance provided in prior IRS notices addressing dispositions of assets subject to section 901(m)—i.e., concerning foreign tax credits and section 901(m) “covered asset acquisitions.”
- Rev. Proc. 2016-56 updates prior IRS guidance and adds new countries—Israel, Korea, and St. Lucia—to the list of countries with which the IRS and Treasury have determined that it is appropriate to have an “automatic exchange” relationship for purposes of reporting payments of deposit interest of $10 or more made by U.S. financial institutions to nonresident alien individuals.
- U.S. employers face uncertainty with respect to healthcare reform under the incoming administration, with indications that there will be changes relating to healthcare reform and federal regulations, including overtime rules.
- The Massachusetts Appellate Tax Board concluded that a company’s failure to apply to be classified as a securities corporation (thereby entitling it to preferential corporate excise tax treatment, and not requiring it to be included in the Massachusetts combined group) precluded the company from such beneficial tax treatment.
- The Portland, Oregon city council is considering an ordinance that, if passed, would impose a surtax on the business license tax liability of certain publicly traded companies, with the revenue to be used to fund social services.
- Washington State’s Supreme Court held that an electronics distributor was liable for B&O tax on receipts from the sales of products that were delivered to Washington customers from an out-of-state warehouse or that were drop-shipped to Washington addresses (i.e., delivered to a third-party in Washington State at the request of the taxpayer’s customer).
- The Uniform Law Commission finalized the Revised Uniform Unclaimed Property Act (RUUPA) with commentary, with application for multiple states.
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- A tax technical corrections bill has been introduced, with measures clarifying the partnership audit rules, real estate investment trust (REIT) and other real estate-related provisions, and various other tax provisions enacted in 2015. The Joint Committee on Taxation (JCT) released its technical explanation of the provisions in H.R. 6439, the “Tax Technical Corrections Act of 2016.”
- The Ways and Means Committee of the House of Representatives announced the release of the 2016 version of the “Green Book”—that provides descriptions and current data about health, welfare, retirement, disability, and related programs under the jurisdiction of Ways and Means.
- The House of Representatives passed by unanimous vote, H.R. 5015, the Combat-Injured Veterans Tax Fairness Act of 2016.
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