United States: Supreme Court Hears Arguments In Challenge To Health Care Premium Tax Credits

The Supreme Court on March 4 heard oral arguments in King v. Burwell, No. 14-114 (2015), which challenges whether taxpayers obtaining health insurance coverage through a federally established insurance exchange can use Section 36B premium tax credits. A successful challenge would eliminate credits for taxpayers in 37 states and would have larger implications for overall health care reform legislation and the excise taxes that employers face when their employees receive coverage.

Under Section 36B, the […]

By |March 19th, 2015|

United States: Transfer Of Partnership Interest Recast Under Substance-Over-Form Doctrine

In a chief counsel advice memorandum (CCA 201507018), the IRS concluded that a transaction involving a partner’s transfer of his partnership interest to a corporation through an organization seeking tax-exempt status should be recast under the substance-over-form doctrine as a direct transfer of the partnership interest by the partner to the corporation. The IRS explained that the tax-exempt organization was never a bona-fide partner because it was entitled only to distributions related to the […]

By |March 18th, 2015|

UK: Deloitte Budget 2015 – Tax-free Annuities For Dependants And Other Beneficiaries

The measure
In the Autumn Statement, the Chancellor announced that individuals who inherited joint life or guaranteed term annuities from a member who died before the age of 75 would no longer be subject to income tax on the payments. This would apply where the death occurred on or after 3 December 2014 and the annuity payments to the beneficiary commence on or after 6 April 2015. This followed previous announcements about tax-free drawdown pensions […]

By |March 18th, 2015|