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State and Local Tax Alert - June 2014

Tue, 06/24/2014 - 12:00am

On June 19, 2014, Rhode Island Governor Lincoln Chafee signed into law H.B. 7133, the budget bill for the fiscal year ending June 30, 2015, which implements combined reporting, single sales factor apportionment, and market-based sourcing of receipts from the sales of services.

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State and Local Tax Alert – June 2014

Tue, 06/24/2014 - 12:00am

Rhode Island Enacts Combined Reporting, Single Sales Factor Apportionment, and Market-Based Sourcing, and Reduces Corporate Tax Rate

State and Local Tax Alert - June 2014

Mon, 06/23/2014 - 12:00am

Legislation enacted in California in 2013 provides that, beginning July 1, 2014, and extending until June 30, 2022, a "qualified" purchaser or lessee of R&D or manufacturing equipment will be eligible to obtain a partial exemption of the sales and use tax.

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State and Local Tax Alert – June 2014

Mon, 06/23/2014 - 12:00am

Manufacturing Exemption Goes Into Effect For Reduced Sales and Use Tax in California Beginning July 1, 2014

International Tax Alert - June 2014

Fri, 06/20/2014 - 12:00am
Certain 25-percent foreign-owned domestic corporations and certain foreign corporations that are engaged in a trade or business in the United States that are required to file Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business
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International Tax Alert - June 2014

Fri, 06/20/2014 - 12:00am

IRS Issues Final and Proposed Regulations to Ease Form 5472 Filing Requirements

State and Local Tax Alert - June 2014

Mon, 06/16/2014 - 12:00am

The Multistate Tax Commission (“MTC”) is taking steps to develop a transfer pricing audit program. State tax officials recently met on June 2, 2014, in St. Louis to discuss the design of the MTC transfer pricing program. The initial draft of the program is expected to be presented at the MTC Executive Committee meeting in December 2014, with the finalized plan to be submitted for ratification during the MTC Executive Committee annual meeting in July 2015. If ratified, implementation should begin thereafter.

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State and Local Tax Alert – June 2014

Mon, 06/16/2014 - 12:00am

The Multistate Tax Commission Takes Steps to Develop a State Transfer Pricing Audit Program

International Tax Alert - June 2014

Tue, 06/10/2014 - 12:00am
United States persons, as defined under applicable banking regulations (and not under federal tax law), are required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (“FBAR”), if they have a financial interest in or signature authority over foreign bank accounts with an aggregate value exceeding $10,000 at any time during the calendar year. The definitions and rules are found in regulations issued by the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) and require that the FBAR filings must be received by Treasury no later than June 30.

Beginning July 1, 2013, all United States owners of foreign bank and financial accounts are required to file FinCEN Form 114 electronically, if the aggregate maximum values of the foreign financial accounts exceed $10,000 at any time during the calendar year. FinCEN Form 114 supersedes Treasury Form TD F 90-22.1 and is available online only through the Bank Secrecy Act Electronic Filing System.
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R&D Tax Alert - June 2014

Tue, 06/10/2014 - 12:00am

On June 2, the United States Treasury Department and the Service issued final and temporary regulations that allow certain taxpayers to elect the section 41 alternative simplified credit (“ASC”) on amended returns. T.D. 9666. Previously, taxpayers could elect the ASC for a taxable year only on that year’s original, timely-filed return. The final regulations eliminate this restriction; the temporary regulations provide that, generally, taxpayers may elect the ASC on amended returns.

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International Tax Alert - June 2014

Tue, 06/10/2014 - 12:00am

Foreign Financial Account Reporting (FinCEN Form 114) Should Be Submitted Electronically No Later Than June 30, 2014

State and Local Tax Alert - June 2014

Fri, 06/06/2014 - 12:00am

The details related to the California competes tax credit next round of tax credits will be announced prior to July 1, 2014.

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Compensation & Benefits Alert - June 2014

Fri, 06/06/2014 - 12:00am
Under the new one-year pilot program that went into effect on June 2, 2014, and ends June 1, 2015, plan sponsors and administrators of certain retirement plans may apply for relief from IRS late filing penalties on past-due annual reports (Form 5500 series). Rev. Proc. 2014-32 provides relief only to plan administrators and sponsors of retirement plans that are subject to the reporting requirements of sections 6047(e), 6058, and 6059, but not the reporting requirements of Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”). Plans with late reports that are subject to Title I of ERISA in addition to these income tax provisions, and therefore not eligible for this relief program, can obtain reduced penalties by entering the Department of Labor’s Delinquent Filers Voluntary Compliance Program.
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State and Local Tax Alert – June 2014

Fri, 06/06/2014 - 12:00am

California Competes Tax Credit Opportunity

Compensation & Benefits Alert - June 2014

Fri, 06/06/2014 - 12:00am

One-Participant and Foreign Plans Maintained Outside the U.S. Might Be Eligible for Relief from Penalties on Past Due Form 5500EZ or Form 5500

State and Local Tax Alert - May 2014

Thu, 05/29/2014 - 12:00am

On May 6, 2014, Pennsylvania Governor Tom Corbett signed into law H.B. 1513, Regular Session 2013-2014 (“H.B. 1513”), which limits the authority of Pennsylvania localities to impose privilege taxes and reduces the potential for double taxation of receipts. The provisions of H.B. 1513 are effective for taxable years beginning on or after January 1, 2014.

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State and Local Tax Alert – May 2014

Thu, 05/29/2014 - 12:00am

Pennsylvania Enacts Legislation Which Limits the Authority of Localities to Impose Business Privilege Taxes and Prevents Double Taxation of Receipts

State and Local Tax Alert - May 2014

Thu, 05/22/2014 - 12:00am

On March 6, 2014, the Ohio Board of Tax Appeals issued its decision in L.L. Bean ,Inc. v. Levin, Tax Commissioner (No. 2010-2853), in which it affirmed the Tax Commissioner’s Commercial Activity Tax (“CAT”) final determination issued to a taxpayer on the basis that the taxpayer had a substantial nexus with the state solely because its taxable receipts exceeded the $500,000 “bright-line presence” standard. The matter is presently on appeal to the Ohio Supreme Court.

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State and Local Tax Alert – May 2014

Thu, 05/22/2014 - 12:00am

The Ohio Board of Tax Appeals Affirmed the Tax Commissioner's Commercial Activity Tax Final Determination Issued to a Taxpayer with Taxable Receipts Exceeding the $500,000 "Bright-Line Presence" Standard

State and Local Tax Alert - May 2014

Wed, 05/21/2014 - 12:00am

On April 1, 2014, Virginia Governor Terry McAuliffe signed H.B. 5001, 2014 Special Session I, which included two new limitations with respect to Virginia’s related member intangible expense add-back requirement:

1. the subject to tax exception only applies to that portion of corresponding income that is attributed to a jurisdiction where the income receiving related member is subject to tax

2. the contracts with unrelated parties exception only applies where the related member actually has contracts with unrelated parties.  These provisions of H.B. 5001 are retroactive to taxable years beginning on or after January 1, 2004.

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