United States: IRS Weighs In Again On Form Versus Substance Of Charitable Contributions; This Time, To Taxpayer’s Disadvantage

The IRS recently determined that a partner’s contribution of partnership units to an exempt organization where the exempt organization then transferred the same units to a corporation owned by the partner was, in substance, a transfer of partnership units from the partner directly to the corporation and, therefore, did not result in a charitable deduction.

The IRS has a long history of reviewing the substance of claimed charitable deductions resulting from the transfer of business […]

By |March 13th, 2015|

Australia: Exploration Development Incentive legislation passes Federal Parliament

In good news for small exploration companies, legislation implementing the Exploration Development Incentive (Incentive) passed the Federal Parliament on 3 March 2015 and is currently awaiting royal assent.

The Incentive allows eligible exploration companies to convert tax losses to ‘exploration credits’ which are then distributed to shareholders who may claim a tax deduction. We discussed the way the Incentive operates in detail in our previous Alert.

To recap the key points:

An exploration company must have no […]

By |March 12th, 2015|

Canada: C.D. Howe Paper: The Taxation Of Single-Employer Target Benefit Plans – Where We Are And Where We Ought To Be

Jana Steele, Ian McSweeney, Barry Gros and Karen Hall recently co-authored the C.D. Howe Paper, The Taxation of Single-Employer Target Benefit Plans – Where We Are and Where We Ought To Be.  The paper offers a blueprint of how tax rules can be changed to better accommodate single-employer target benefit plans (TBPs).

Many employers have been looking for alternatives beyond traditional pension arrangements to better manage their pension risks. TBPs are an attractive hybrid of […]

By |March 12th, 2015|