10-Q&A Episode 6: Interview with Mike Rios and Louis Couture, Temple Law Students and ABA Tax Section Competition Winners
Jon Shahar sits down with ABA Tax Section Competition Winners, Mike and Louis (LAW ‘21).
Tax
When S Corporations Should Elect Entity Treatment for GILTI Purposes
This article analyzes Notice 2020-69 and the S corporations and shareholders that would benefit from electing entity treatment for the global intangible low-taxed income (GILTI) regime.
Temple Launches New Center For Tax Law and Public Policy
Professor Alice Abreu outlines the purpose and mission of the newly formed Temple Law School Center for Tax Law and Public Policy.
Proposed Regulations Broaden Limitation on Compensation Deductions for Public Companies
John Eagan (LAW ’79) and Stephen Bowers of White and Williams, LLP, discuss a few proposed regulatory changes under Internal Revenue Code Section 162(m), which limits the amount of compensation to certain individuals that a publicly traded company may deduct as a business expense.
Chief Judge Maurice Foley of the U.S. Tax Court: Fall 2019 Fogel Lecture
On November 20, 2019 Chief Judge Maurice Foley of the U.S. Tax Court delivered this year’s Fogel Lecture at Temple Law School, which he dubbed “Pathways and Pitfalls, A Candid Discussion of My Path to the Bench.” Before becoming the first African-American appointed to the United States Tax Court in 1995, Judge Foley was an attorney for the Legislation and Regulations Division of the Internal Revenue Service, Tax Counsel for the United States Senate Committee on Finance, and Deputy Tax Legislative Counsel in the U.S. Treasury’s Office of Tax Policy.
Tax Relief May be Ahead for Market Participants Transitioning Away from LIBOR
Tax relief may be coming for issuers and holders of debt instruments and parties to derivatives and other financial contracts governed by LIBOR (the London Interbank Offered Rate). The IRS published new proposed regulations on October 9 to address tax concerns as parties have begun to modify financial instruments’ reference rates in anticipation of a
Preparing for a “Looming” Recession: Practical Tips for Lenders
White and Williams attorneys discuss steps the commercial lending industry can take to prepare for recession.
Tax 2018: Requiem for Ability to Pay
Temple Law Professor, Alice Abreu, discusses tax reform changes this tax season.
Dana Trier: 2019 Fogel Lecture
In the 2019 Fogel Lecture, Dana Trier, former Deputy Assistant Secretary for Tax Policy at the U.S. Department of the Treasury, urged the audience to give the “grand experiment” of §199A of the 2017 Tax Cuts and Jobs Act (which provides a deduction for qualified business income from pass-through entities) a chance, despite potentially troubling ambiguities.
NJ Appellate Court Affirms Decision Denying Interest Expense Addback Exception
The New Jersey Superior Court, Appellate Division, has affirmed the Tax Court’s decision in Kraft Foods Global Inc., in which a taxpayer’s deduction for related-party interest expense was disallowed for corporation business tax purposes (decision available here). Background The only issue before the court was whether the Division of Taxation (the “Division”) properly added back