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Practical Insights for In-house Tax and Finance Professionals |
3/10/2010
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Petit déjeuner
Fiscalité |
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En période de sortie de crise, la fiscalité est au premier plan des préoccupations des entreprises, au même titre que les questions commerciales, financières et purement juridiques. Le gouvernement a donc eu la lourde tâche de concilier les mesures destinées à encourager l’investissement avec de nouvelles dispositions ayant vocation à contrecarrer les optimisations fiscales abusives qui ont fait l’actualité de ces dernières années.
De l’impôt sur les sociétés à la nouvelle contribution économique territoriale, en passant par la TVA et l’impôt sur le revenu, l’équipe des avocats fiscalistes de Nixon Peabody est heureuse de vous convier à un panorama des récentes évolutions législatives, jurisprudentielles et réglementaires afin, comme chaque année, de vous assister dans l’adaptation de votre stratégie fiscale d’entreprise mais aussi personnelle.
Tax Breakfast
When recovering from an economic downturn, tax issues are a key concern to companies, as are matters concerning trade, financial, and legal issues. The French government has therefore had the difficult task of reconciling the measures introduced to encourage investment with the measures contemplated to counter the excessive tax optimization practices that have been making the news in recent years.
From corporate tax to the new territorial economic tax contribution, as well as VAT and income tax, Nixon Peabody’s specialized team of tax lawyers is pleased to invite you to an overview of recent evolutions in tax, case law, and regulatory rules so as to assist you, as is our annual tradition, in adapting your corporate, as well as personal, tax strategy.
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Date
Mercredi 17 mars 2010
Wednesday, March 17, 2010
Horaire/Time
8h30: Accueil et petit déjeuner
9h: Conférence
8:30 a.m.: Registration and breakfast
9:00 a.m.: Conference
Lieu/Place
Nixon Peabody
Centre de conférence
Capital 8
32 rue de Monceau
75008 Paris
RSVP
(places limitées/seating is limited)
Inscrivez-vous en ligne.
Register online.
Contact
Pour tout renseignement, merci de contacter
Clément Pelletier par e-mail : cpelletier@nixonpeabody.com ou tél : +33 (0)1 70 72 36 39.
For more information, please contact Clément Pelletier at cpelletier@nixonpeabody.com or +33 (0)1 70 72 36 39. |
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32 rue de Monceau • 75008 Paris, France
www.nixonpeabody.com |
 |  3/3/2010
By David Cheng, Yanwen Le, and Henry Liu
It appears that the Chinese tax authorities have taken an interest in foreign holding companies operating in China. The Chinese State Administration of Taxation (SAT) released a notice (Notice 698) on 15 December 2009 that addresses the transfer of shares of nonresident companies. Notice 698 is effective retroactively from January 1, 2008. It does not apply to the sale on a public securities market. It is common practice for foreign investors to invest in Chinese companies through an interposed foreign holding or operating company, like a Cayman Islands or Hong Kong-based company. Reasons for this structure include, among others, both tax and business purposes, for example, avoiding the lengthy approval and registration process required for a direct transfer (i.e., without a foreign holding or operating company) of an equity interest in a foreign invested Chinese company. In other words, under this structure, a foreign investor can indirectly transfer its interest in the Chinese company by transferring its interest (i.e. sale of stocks) in the foreign holding or operating company (which in turn holds interest in the Chinese company) without complying with Chinese government registration requirement or obtaining the Chinese government approval.
The Chinese tax authorities recently announced in Notice 698 their intention to scrutinize such transaction, including those occurring entirely outside of China between foreign sellers and buyers. Under Notice 698, the foreign investor must disclose such transaction if the foreign holding or operating company (which in turn holds interest in Chinese companies) is located in a jurisdiction that is low taxed or does not tax foreign source income (ex. potentially Cayman Islands or Hong Kong-based holding or operating companies). According to Article 5 of Notice 698, when a foreign investor (actual controlling party) indirectly transfers the equity of a Chinese resident enterprise, if the actual tax burden in the country (region) where the overseas holding company being transferred is located is less than 12.5%, or the aforesaid country (region) does not levy income tax on its residents’ overseas income, it shall, within 30 days from the date when the equity transfer contract is concluded, provide the relevant materials and information to the competent taxation authority where the Chinese resident enterprise whose equity is transferred is located.
The information that is required to be disclosed covers not only equity transfer agreements, but also information of the relationship between the foreign investor and the overseas holding company, between the holding company and resident company, explanation on the reasonable business purpose for the foreign investor to establish the overseas holding company, etc. Relying on such disclosure, the Chinese tax authorities will determine whether the transaction lacks commercial (i.e., business) purpose, resulting in the avoidance of China Enterprise Income Tax ("EIT") withholding. Specifically, it appears that the Chinese tax authorities would likely focus on the business purpose of the foreign holding company, examining whether it has commercial purpose and substance for its establishment and maintenance, other than tax savings. If not, the Chinese tax authorities may disregard the form of the transaction. In other words, the foreign holding or operating company may be disregarded and the foreign investor would be treated as having income from the direct transfer of an equity interest in a Chinese company, thereby generating Chinese source income subject to Chinese tax.
Since the Notice has been recently issued, it is too early to draw a conclusion on how it will be implemented. There will be issues and difficulties, in particular, that may practically impede the implementation of the Notice. The Notice has left behind some uncertainties that will need to be clarified (e.g. how 12.5% tax rate is calculated). Enforcement difficulties will also arise for offshore transfers in practice. How will the Chinese tax authorities monitor such offshore transfers while the withholding agents are unable to be identified? It will also be legally challenging to require foreign companies to submit to the Chinese government information that may not be relevant to Chinese companies. According to Article 10, this Notice shall come into force retroactively on January 1, 2008. This means that nonresident investors that disposed of Chinese companies indirectly even two years ago should review their transactions to see whether additional compliance is required. In view of this Notice, foreign investors should review their China investment structures to determine how best to reinforce their business purpose and commercial substance.
For more information please contact:
2/9/2010
By Sarah Nelson
The Obama Administration’s Fiscal Year 2011 Revenue Proposal (the “Revenue Proposal”) includes three amendments to the Internal Revenue Code of 1986 (the “Code) which, if enacted, would provide tax cuts for certain businesses and investors.
1. Elimination of Capital Gains Tax on Investments in Small Business Stock
The Revenue Proposal amends Section 1202 of the Code thereby eliminating capital gains taxation on gain on the sale of certain small business stock that was acquired at the original issuance and was held for at least five years. Presently, only 50% of such gain is subject to tax (25% for qualifying stock acquired between February 17, 2009 and January 1, 2011). Additionally, the proposal removes any portion of such gain from being subject to the alternative minimum tax (AMT). In order for capital gain to be eligible for this exclusion, the related corporation, at the time the stock is issued, may not have gross assets exceeding $50 million (including the proceeds of the newly issued stock) and may not be an S corporation. Excludible gain may not exceed the greater of (1) ten times the taxpayer’s basis in stock issued by the corporation and disposed of during the year or (2) $10 million (reduced by previously excluded capital gain on the disposition of such corporation’s stock). The proposal would be effective for qualified small business stock acquired after February 17, 2009.
2. Research and Experimentation Tax Credits
The research and experimentation tax credit (the “R&E Tax Credit”) provisions expired on December 31, 2009. The Revenue Proposal would permanently reinstate the R&E Tax Credit which provides a tax credit for 20% of qualified research expenses above a base amount. The proposal would be effective as of January 1, 2010.
3. Remove Cell Phones From Listed Property
The Revenue Proposal removes cell phones (and other similar telecommunications equipment) from being classified as “listed property” for purposes of Section 274 of the Code. Presently, the deduction for ordinary and necessary business expenses is disallowed for “listed property” unless the use of the property is substantiated by sufficient evidence. This disallowance includes the expense of providing cell phone to employees. Similarly, taxpayers who receive cell phones from their employers must include the fair market value of the portion of personal usage of the cell phone in their gross income. The proposal would remove the documentation requirements required for employers to take deductions and depreciation deductions for the cost of providing cell phones and would remove the employee’s obligation to include the personal use value of such cell phone in their gross income. The proposal would be effective as of the date of enactment.
For more information, please contact Sarah Nelson at 212-940-3052 or snelson@nixonpeabody.com.
2/2/2010
By Robert Thompson
One of the major tax cuts for business in the Administration’s Fiscal Year 2011 Revenue Proposals is a proposal to cut taxation on investments in qualified small business stock. Under current law there is an exclusion of 50% of the gain recognized on the sale by an individual and certain other non-corporate taxpayers of qualified small business stock held for more than five years. The 50-percent exclusion provision provides little benefit under current law, however, because the taxable portion of gain from the sale is subject a maximum tax rate of 28 % (instead of the regular 15% rate) and a percentage of the excluded gain is a preference under the alternative minimum tax ("AMT'). The new proposal would increase the exclusion to 100% and eliminate the preference under AMT. The provision would apply to stock acquired after February 17, 2009. Existing law definitions, limitations and requirements for the 50% exclusion under current law apparently would continue to apply, including the five year holding period requirement. For example, the provision would not apply to certain service businesses and other enumerated businesses, and the amount of gain eligible for the exclusion in any one year is capped at the greater of 10 times the original investment or $10 million less gain excluded in prior taxable years. A small business is generally one whose gross assets do not exceed $50 million at the time of the stock issuance. Other rules apply as well.
The provision would greatly benefit entrepreneurs and their financiers, such as angel investors and venture capital funds. The benefit may not apply, however, to sponsors of the venture capital funds, if carried interest legislation is passed to tax their share of capital gains as ordinary income. One interesting note is that only stock in a C corporation can qualify for the exclusion. Historically, pass-through entities, such as LLCs and S corporations, are often chosen as the form of entity to operate a small business, primarily to achieve one level of taxation on income. Given the proposed increase in the highest marginal tax rates on individuals that may apply to much of the income generated by small businesses operating as flow through entities, the added benefit of a potential 100% gain exclusion from the qualifying sale of qualified small business stock of a C corporation, may tilt some small business owners and their investors to operate their business as a C corporation. Moreover, the existing provisions permitting rollover of certain gains from the sale of qualifying small business stock would apparently also remain available.
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Join us online Thursday, February 4, 2010, at noon, Eastern time, for our Multistate Tax Forum |
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Many of you have attended our in-person tax forums in Rochester, Boston, and Washington, so you are familiar with the format. We’ve now moved them completely online and gone national, so our tax clients outside those three cities can participate, either by web conference or conference telephone.
For those of you who have never attended before, here’s the idea:
- Nixon Peabody lawyers make very brief comments about a few current events. No sales pitches.
- Most of the time is devoted to the roundtable— you and your fellow corporate tax professionals report on current tax audits and litigation, react to the current events reported by others, share ideas and best practices, and ask questions of the group. It’s your roundtable, and an opportunity to expand your peer network.
- Attendance is by invitation only, and is limited to in-house corporate tax professionals. We occasionally have participation from the staff of COST (Council on State Taxation) but never from any other law or accounting firms, no government people, no vendors, etc. This policy will be continued in the online format, and you will know exactly who every other online participant is at all times.
- Attendance is free to invitees, and we are usually able to provide 2 hours of CLE credit, depending on your state’s rules. We also know that we can provide New York CPA’s with two hours of CPE credit, but that not all states allow credit for webinars. Let us know what state’s credit you need, and we will apply for it.
The initial brief presentations at our February 4 meeting will cover: (1) the recent announcement by the IRS unveiling a proposal for a tax schedule that would require certain taxpayers to proactively report their uncertain tax positions and the associated dollar amounts at the time they file their returns; and (2) the Praxair case out of New Jersey and its impact on voluntary disclosure and amnesty programs. If you have questions about current best practices in this area, or if you can share yours, this is the ideal opportunity.
Kindly RSVP with your full contact information using the link on the right. Feel free to pose any questions to Denise Ivery at divery@nixonpeabody.com or 202-585-8366.
Note: To assure the security of the online meeting facility, you must be registered in advance to attend. No one will be admitted at the (virtual) door. A follow-up invitation will be sent to all registered participants with a Webex registration link. Once you complete your Webex registration, you will receive an e-mail from Susan Boudreaux containing your unique link and password for joining the webinar. Please save this e-mail with your unique link and password, as you will need it to join the meeting the day of the webinar. |
Date
Thursday, February 4, 2010
Time
12:00–2:00 p.m. Eastern
Location
Online webinar (Secure webinar link and password will be e-mailed to all registrants prior to the webinar)
RSVP
Register online.
Contact
For more information, please contact Denise Ivery at divery@nixonpeabody.com or 202-585-8366.
Nixon Peabody is an accredited provider of continuing legal education in New York, California, New Hampshire and Rhode Island. Per New York State rules, this program is approved for 2.0 general credit hours and is approved for experienced attorneys only. For other jurisdictions where reciprocity does not apply, individuals are responsible for seeking course approval from their state CLE boards. Nixon Peabody will assist with seeking course CLE approval upon request. Please note that the CLE Boards have the final authority on the acceptance and granting of CLE credit for individual courses. Attendees are responsible for self-reporting their CLE credits. This program is approved for 2.0 Taxation CPE credits in New York (program not preapproved for CPE credits by NASBA). | |
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401 Ninth Street NW • Washington, DC 20004 • 202-585-8000
www.nixonpeabody.com |
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If you would like to be removed from our mailing list,
please contact Denise Ivery at divery@nixonpeabody.com or 202-585-8366. 1/14/2010
Surprisingly, Congress took no action in regard to the federal estate tax before the end of last year. As a result, current law provides for a temporary, one-year repeal of the tax, with a return in 2011 to the tax rules that prevailed in 2001, featuring a $1 million exemption amount and a top marginal rate of 55% for both the estate and gift taxes. Complicating the situation is congressional chatter suggesting that legislation will be passed sometime early this year, retroactive to the first of the year, reinstating some form of the estate tax for 2010.
If Congress does not act, here is a summary of the rules for 2010 only:
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There is no federal estate tax for people who die in 2010.
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There is no generation-skipping transfer (GST) tax for generation-skipping transfers that occur in 2010.
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The federal gift tax continues, with a $1 million exemption for lifetime gifts and a maximum rate of 35% (versus 45% in 2009).
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State estate taxes continue as they were. (As examples, Massachusetts and New York both have their own, independent estate taxes with exemptions of $1 million, while Florida has no estate tax.)
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New “carryover basis” rules apply for people who die in 2010, so assets passing from a decedent will no longer automatically receive a basis “step-up” for capital gains purposes. Instead, the new basis rules allow the executor of an estate to allocate up to $1.3 million of “increased basis” to any property passing from a decedent who dies in 2010, plus an additional $3 million of increased basis to property passing to a surviving spouse as “qualified spousal property.” Otherwise, assets will retain their pre-death basis.
If Congress does take action to “repeal the repeal,” it is impossible to predict with any certainty what rules will apply in 2010. Nevertheless, there are some signs the rules that prevailed in 2009 may be extended through 2010. (The House, but not the Senate, passed such legislation in mid-December and Senate Finance Committee Chair Max Baucus has stated that the Senate intends to extend the estate tax provisions without a gap in coverage.) By way of reminder, the 2009 rules provided for a $3.5 million exemption amount and a top marginal rate of 45% for both estate and generation-skipping taxes, a top gift tax rate of 45% , and a step-up in basis for any assets included in a decedent’s estate. After 2010, it remains unclear whether we will revert to the 2001 rules.
During this period of uncertainty, we are particularly concerned about existing estate planning documents that rely on formulas tied to the amounts of the federal estate tax exemption (such as commonly used “credit shelter formulas” or formulas for funding marital deduction gifts) or tied to the amount of the GST tax exemption. These formula gifts are dependent upon tax concepts that may not exist at the time of the person’s death, potentially causing intended gifts to fail or unnecessary taxes to be incurred. Another concern is whether our married clients have appropriately titled their assets, given the way increases in basis can be obtained (or not) under the new carryover basis rules.
We would welcome the opportunity to talk with you about your current estate planning documents to ensure they properly carry out your intentions in light of these significant changes in the tax laws.
For more information, please contact:
John L. Garrett at 585-263-1271 or jgarrett@nixonpeabody.com
1/12/2010By Susan P. Reaman
Among the many welcome changes to the low-income housing credit program under the Housing and Economic Recovery Act of 2008 (“HERA”) was the establishment of the Capital Magnet Fund (CMF). With direct funding of $80 million under the president’s 2010 budget, the CMF will provide grants to finance affordable housing and related community development projects. Eligible grantees include community development financial institutions (CDFIs) and nonprofit organizations having the development or management of affordable housing as one of their principal purposes.
The CMF was established as a permanent trust fund and will be administered by the Treasury Department’s Community Development and Financial Institutions (CDFI) Fund. The CDFI Fund administers other grant programs, including the CDFI Grant Program which provides financial and technical assistance to CDFIs serving low-income people and communities and the New Markets Tax Credit Program, which provides investors a tax credit for investing in businesses located in under-served areas.
As its name suggests, CMF grant dollars are to be used to attract private capital for and increase investment in the development, preservation, rehabilitation, or purchase of affordable housing primarily for extremely low-, very low-, and low-income families, and related economic development activities or community service facilities such as day care centers, workforce development, and health care clinics.
Awards of CMF grants are intended to stabilize and revitalize low-income or under-served rural areas. Grantees may use grant monies to establish loan loss reserves, to capitalize a revolving loan fund, an affordable housing fund, or a fund to support economic development activities or community service facilities, and to provide risk-sharing loans.
In March 2009, the CDFI Fund published a Request for Public Comment on how the CDFI Fund should design, implement, and administer the CMF. In July 2009, the CDFI Fund released, on its website (www.cdfifund.gov), 37 comment letters it received in response to its request for public comment. Many commentators urged the CDFI Fund to use definitions and criteria from existing programs, such as the CDFI Grant Program, to fashion similar rules for the CMF. As for what constitutes “affordable housing,” many commentators suggested that housing units meet the income, rent, or purchase price term requirements of either the Low-Income Housing Tax Credit (LIHTC) for rental properties or the HUD HOME Investments Partnerships Program for rental and home ownership. At least one commentator suggested that a percentage of the affordable housing funding be used for workforce housing or specific populations, including but not limited to artists, teachers, firefighters, and police officers. The CDFI Fund specifically asked for comments on whether it should support economic development activities, and/or community service facilities in conjunction with affordable housing activities financed by sources other than CMF grants such as the LIHTC, HOPE VI, or private sources.
The CDFI Fund will administer competitive application rounds to distribute CMF grants. Officials from the CDFI Fund estimate that an Interim Final Rule should be released this year as early as late February. A final application should be published shortly thereafter. Administration of the CMF program will most likely be similar in many respects to the CDFI Grant Program.
On its website, the CDFI Fund describes some of the information that the application will require, including: a detailed description of the types of affordable housing, economic, and community revitalization projects the grantee would fund with a grant through the CMF; the specific use of grant funds; the types, sources, and amounts of other funding for such projects; and the timeframe for use (deployment) of grant funds.
In addition, selection criteria, prioritization, and compliance requirements must ensure that the CMF grants support activities in geographically diverse areas, including (to the extent practical) metropolitan and under-served areas in every state.
As required under the HERA, no more than 15 percent of the aggregate amount of funds available in a given round may be awarded to any one grantee (or its affiliates and subsidiaries); grantees must leverage their CMF awards by at least 10 times the award amounts; and the grant funds must be committed for use within two years of allocation. We expect clarification of these statutory criteria will be forthcoming under the Interim Final Rule and application.
The funding of the CMF comes at a critical time for developers in the affordable housing industry who are eager to jumpstart the industry in 2010. Grants available through the CMF Program provide yet another government economic tool toward realizing that goal.
Please feel free to contact your regular Nixon Peabody attorneys, or Susan P. Reaman at 202-585-8327 or sreaman@nixonpeabody.com, with your thoughts and questions. We look forward to hearing from you.
12/22/2009
Rare is the circumstance where a state taxing authority feels compelled to blog about a nexus case. In its July 23, 2009 post entitled "Another Point of View on Town Fair Tire", the Massachusetts Department of Revenue (DOR) blogged:
"To say there has been more heat than light generated in the ongoing news coverage of the Town Fair Tire sales tax case would be an understatement ... In truth, the Town Fair Tire dispute is a narrow case testing whether Massachusetts has the right to compel the tire company, which also has stores in Massachusetts and is thus subject to Massachusetts rules, regulations and laws, to collect sales tax on tires installed [in New Hampshire] on vehicles bearing Massachusetts license plates and registrations."
If this case is so narrow, why would the DOR focus its resource-constrained efforts on a case with a liability of approximately $108,000 on the original assessment that included tax, interest and penalties? The Boston Globe dubbed the case "Taxachusetts" versus the "‘Live Free or Die’ pride of New Hampshire." Kevin W. Brown, general counsel of the Massachusetts DOR, was quoted in this same news article as saying the case attempts to address a difficult and protracted problem that seeks to protect Massachusetts retailers. According to the story, some economists have estimated this to be somewhere between a $130m and $410m annual problem for Massachusetts.
Retailer had no duty to collect Massachusetts sales tax for out-of-state purchases by Massachusetts residents
In Town Fair Tire Centers, Inc. v. Commissioner of Revenue, SJC-10360, 8/25/2009, the Supreme Judicial Court of Massachusetts held that a store located in New Hampshire did not have to collect Massachusetts sales tax from customers who bought goods in New Hampshire but had a Massachusetts address, driver’s license or telephone number. The Court interpreted the relevant Massachusetts statute, G. L. c. 64I, §4, to impose sales tax liability only once the property was actually stored, used or consumed in Massachusetts. Since the customers who bought tires in New Hampshire did not use them in Massachusetts before leaving the store, the store had no obligation to collect Massachusetts sales tax. The Court held that the Commissioner may not presume that Massachusetts customers would use the tires in Massachusetts, because the sales tax statute does not explicitly allow such a presumption.
The decision rests on statutory interpretation and not on constitutional grounds, and the Court emphasized that the Massachusetts Legislature could amend the statute to impose a sales tax in similar circumstances in the future. In fact, the Court pointed out that several other states already impose sales tax in cases when the vendor knows that the purchaser is a resident of the taxing state. Given the current budget shortfalls, we may see Massachusetts and other states enact similar statutes to force out-of-state vendors to collect sales tax on purchases by in-state residents.
New Hampshire’s Response
New Hampshire Governor John Lynch proposed legislation to protect New Hampshire’s businesses from having to collect sales taxes on behalf of Massachusetts. From the release announcing his proposed legislation, Governor Lynch said, "We have chosen not to have a sales tax here in New Hampshire, and we are not about to let Massachusetts – or any state – impose its sales tax on our businesses for items purchased in New Hampshire stores." The final version of the legislation proposed by Governor Lynch that took effect in July of 2009 provided that business owners cannot be compelled to disclose private customer information and that unless the consumer gives information on his own, there is a "presumption" that New Hampshire is where the purchased goods will be used. 12/15/2009
By Christian McBurney
On December 9, 2009, the House of Representatives passed the Tax Extenders Act of 2009 (H.R. 4213) (the "Act") with the purpose of extending through 2010 various popular tax benefits. To pay for the tax extenders, the House also passed legislation that would tax carried interests of private equity funds, hedge funds, real estate funds and other investment funds at the rates applicable to ordinary income (as opposed to current capital gains rates). The effective date would be tax years ending after December 31, 2009. The legislation adopted is essentially the same as the Levin bill. Accordingly, the House did not adopt the Obama administration's proposal to subject all carried interests to ordinary income treatment; this bill only applies to private equity and other investment funds. This independence on the part of House Democrats is consistent with the Obama administration's general stance of not insisting that Congress enact legislation precisely as it has proposed, so long as the gist of the legislation is passed. The prospects for the carried interest legislation in the Senate are not clear. Typically, the revenue-raising provisions for a tax extenders bill are not controversial, but in this case there has been no indication of a consensus in the Senate that carried interest legislation should pass. It is likely at the least that the tax extenders bill will not be quickly passed by the end of this year. On the other hand, pressure will build to renew the popular tax benefits in the tax extenders bill for another year. We will continue to monitor the legislation.
The IDC Research case in Massachusetts is another signal from state tax authorities of increased audit enforcement on transfer pricing issues. Although the facts of the case are narrow, the decision is important for two reasons: (1) the taxpayer won without a contemporaneous transfer pricing study; and (2) this if first reported decision in Massachusetts looking to IRC Code Section 482 for intercompany pricing guidance. | Check Effective Permissions | | /globaltaxblog/_layouts/SecurityReportAccount.aspx?id={ItemId}&List={ListId}&Type=ListItem | 0x40000000 | 0x0 | ContentType | 0x01 | 10 |
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