United States

The Tax Exchange

Tax discussions for the business leader


Ohio CAT situsing: avoiding the hot tin roof with recent guidance

Ohio CAT situsing: avoiding the hot tin roof with recent guidance

Recently, the Ohio Board of Tax Appeals issued a decision addressing the situsing of sales under the state’s Commercial Activity Tax (CAT). In Greenscapes Home and Garden Products, Inc. v. Testa, the board found that an “ultimate destination” test is the key inquiry in determining whether sales of tangible personal property should be sitused to the state.

  • August 07, 2017
Key differences between redemption and sale of partnership interests

Key differences between redemption and sale of partnership interests

There are substantial tax differences between a redemption (a partner is redeemed out by the partnership) and a sale of a partnership interest.

  • August 03, 2017
Republican health care reform efforts blocked in the Senate

Republican health care reform efforts blocked in the Senate

On July 28, 2017, the Senate voted against a Republican health care bill known as the Health Care Freedom Act. The Health Care Freedom Act was the Republican’s latest draft of legislation to modify the Affordable Care Act (ACA).

  • August 01, 2017
Tax Court tosses aside IRS guidance

Tax Court tosses aside IRS guidance

The Tax Court recently ruled that the redemption of a foreign person’s interest in a U.S. partnership was neither U.S. source income, nor income effectively connected with a trade or business. As a result, the taxpayer was largely not liable for U.S. tax.

  • July 31, 2017
Seattle creates waves by passing tax on high-income earners

Seattle creates waves by passing tax on high-income earners

In what Mayor Ed Murray has called a “new formula for fairness” and a challenge to the state’s “antiquated and unsustainable tax structure,” Seattle recently became the first local jurisdiction in Washington state to pass an income tax when it was approved by city council and signed by the mayor in mid-July.

  • July 28, 2017
International tax reform, where do we stand?

International tax reform, where do we stand?

Fall is around the corner and Congress’ progress on tax reform leaves much to be desired. Earlier in the year we were hopeful for comprehensive tax reform in 2017, now we are cautiously optimistic for even a minor reform package to come by the end of 2018.

  • July 26, 2017