- On July 21, 2014, the Federal Deposit Insurance Corporation (FDIC) issued Financial Institution Letter FIL-40-2014. The guidance clarifies how the FDIC will evaluate requests by S-Corporation banks to make shareholder dividend payments to cover taxes on their pass-through share of the bank's earnings. Without FDIC approval, these dividends would not be permitted under the capital conservation buffer requirements in the Basel III rule.
- On May 9, 2014, the IRS Office of Chief Counsel issued a memorandum discussing the tax treatment for payments that auto dealerships receive from manufacturers from facility image upgrade programs.
- As a result of additional regulatory requirements, merger and acquisition discussions and activity are increasing in the banking industry. Associated transaction costs incurred related to a merger or acquisition transaction can be significant. These costs can include fees for financial advice, legal services, due diligence services, and expenses to arrange debt financing and can greatly impact a company’s financial statement.
- Jim Alajbegu, Baker Tilly International Tax Firm Leader, discusses tax inversions with Chitra Nawbatt, anchor and correspondent for CTV News.
- In the recently published Revenue Ruling 2014-18, the Internal Revenue Service (IRS) concluded that certain nonqualified stock options (NSOs) or stock appreciation rights (SARs) would not be subject to the anti-deferral rules of Internal Revenue Code section 457A (section 457A). Generally, section 457A prohibits the deferral of income for service providers that perform services for nonqualified entities (i.e., foreign corporations based in offshore tax havens, entities substantially owned by tax-exempt organizations, or other tax-indifferent parties).
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