United States: Court Affirms IRS Position On Foreign Tax Credit Statute Of Limitations

In Albemarle Corporation & Subsidiaries v. U.S., No. 12-184T (Ct. Cl. 2014), the taxpayer, Albemarle, a domestic corporation, filed a complaint in the U.S. Court of Federal Claims seeking a refund for taxes paid in the 1997 and 1998 tax years. The taxpayer alleged that the IRS incorrectly disallowed its refund claims for foreign tax credits related to its Belgian subsidiary, Albemarle S.A. The government filed a motion to dismiss, stating that the complaint […]

By |October 20th, 2014|

United States: Tax Reform Act Of 2014 And The Charitable Deduction

Laws and Regulations
Representative Dave Camp, the current chair of the House Ways and Means Committee (the “Committee”), introduced a discussion draft of the Tax Reform Act of 2014 (the “Camp Bill”) on February 26, 2014. Although it is widely predicted that the Camp Bill will not pass, exempt organizations should still examine it closely, because it is emblematic of a new trend in legislative proposals dealing with tax reform.

Changes at the margins of the […]

By |October 19th, 2014|

United States: IRS Releases Highly Anticipated Cash Balance Plan Regulations

Background
The U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently released long-awaited final regulations (the Final Regulations) with respect to market rates of return and related Pension Protection Act (PPA) requirements applicable to pension equity plans (PEPs) and cash balance plans (collectively, hybrid plans).  The Final Regulations make certain key changes to final and proposed regulations issued by the IRS in 2010 (the Prior Regulations), as described below.  In addition, Treasury […]

By |October 19th, 2014|