United States: Tennessee Tax Department Releases Letter Rulings

The Tennessee Department of Revenue recently released several Letter Rulings analyzing various Tennessee tax issues, including the application of sales and use taxes to cloud collaboration services and software consulting services, the application of the Hall income tax to cash distributions received by an employee shareholder, and the availability of the franchise and excise tax industrial machinery credit. An analysis of these rulings and practice point comments are set forth below.

Cloud Collaboration Service Subject to […]

By |November 23rd, 2014|

UK: Inflation Adjustments To Transfer Tax Provisions Provide New Opportunities In 2015

On October 30, 2014, the IRS announced in Rev. Proc. 2014-61 that there will be higher estate, gift, and generation-skipping transfer (GST) tax exemptions for tax year 2015 to account for inflation.  These new thresholds provide additional estate planning opportunities to pass assets free from federal transfer taxes.
The Inflation Adjusted Numbers
The IRS’s annual inflation adjustments modify more than forty provisions in the tax code.  As these relate to future estate planning opportunities, three provisions […]

By |November 22nd, 2014|

United States: Tax Court Rules Corporate Merger Of Family-Owned Businesses Results In Substantial Taxable Gift

In September, the Tax Court issued its opinion in Cavallaro v. Commissioner, T.C. Memo 2014-189, holding that a merger of two family-owned businesses resulted in a $29.6 million gift from Mr. and Mrs. Cavallaro to their three sons.
Background
Mr. Cavallaro started a tool manufacturing company called Knight Tool Co. (“Knight”). Knight was co-owned by Mr. and Mrs. Cavallaro. As his sons became adults, all three were  involved in the business. In the 1980s, Knight developed […]

By |November 22nd, 2014|