New Law. The Act retroactively and permanently extends the 100% exclusion and the exception from minimum tax preference treatment.
New Law. No statute, rule or regulation shall have been enacted by the government (or any governmental agency) of the United States or any state, municipality or other political subdivision thereof that makes the consummation of the Merger and any other transaction contemplated hereby illegal.
New Law. For Participants other than Five-Percent Owners, the April 1 of the calendar year following the later of the calendar year in which the Participant attains age 70-1/2 or the calendar year in which the Participant retires. For a Five-Percent Owner, the April 1 of the calendar year following the calendar year in which the Participant attains age 70-1/2. (If (b) is selected, complete the following:)
New Law. The Parties recognize that City presently is required by law to defend the validity of any voter-approved City initiative or referendum. The undertaking and provision of any such defense by City shall not be construed in any manner as a violation or default of this Agreement.
New Law. The Act retroactively and permanently extends the rules exempting from gross basis tax and withholding tax the interest-related dividends and short-term capital gain dividends received from a RIC. Treatment of RIC As Qualified Investment Entity Permanently Extended Gain from the disposition of a U.S. real property interest (USRPI) by a foreign person is treated as income effectively connected with a U.S. trade or business and is subject to tax and to withholding under the Foreign Investment in Real Property Tax Act (FIRPTA) provisions. A USRPI does not include an interest in a domestically controlled "qualified investment entity". Under pre-Act law, before January 1, 2015, a RIC that met certain requirements could be treated as a "qualified investment entity". New law. The Act retroactively and permanently extends the inclusion of a RIC within the definition of a "qualified investment entity." The change made generally takes effect on January 1, 2015, but the Act doesn't impose a withholding requirement for any payment made before its enactment. A RIC that withheld and remitted tax on distributions made after December 31, 2014 and before the enactment date isn't liable to the distributee for such withheld and remitted amounts.
New Law. The Act retroactively and permanently extends the credit. And, for tax years beginning after December 31, 2015, the Act provides that the credit applies to employers of any size (i.e., the less than 50 employee average no longer applies).
New Law. The Act retroactively extends the WOTC so that it applies to eligible veterans and non-veterans who begin work for the employer before January 1, 2019. With respect to individuals who begin work for an employer after December 31, 2015, the credit also applies to employers who hire qualified long-term unemployed individuals (i.e., those who have been unemployed for 27 weeks or more). The credit with respect to such long-term unemployed individuals is 40% of the first $6,000 of wages. Look-Through Rule for Payments Between Related CFCs under Foreign Personal Holding Company Income Rules Extended Through 2019 For tax years beginning before January 1, 2015, dividends, interest, rents, and royalties received by one controlled foreign corporation (CFC) from a related CFC are not treated as foreign personal holding company income (FPHCI) to the extent attributable or properly allocable to non-subpart-F income, or income that was not effectively connected with the conduct of a U.S. trade or business of the payor (look-through treatment). Under pre-Act law, this look-thru rule applied to tax years of foreign corporations beginning after December 31, 2005, and before January 1, 2015, and to tax years of U.S. shareholders with or within which such tax years of foreign corporations ended. New law. The Act retroactively extends look-through treatment for related CFCs for two years, to tax years of a foreign corporation before January 1, 2020, and tax years of U.S. shareholders with or within which such tax years of foreign corporations end. New Markets Tax Credit Extended Through 2019 A new markets tax credit applies for qualified equity investments to acquire stock in a community development entity (CDE). The credit is: (1) 5% for the year in which the equity interest is purchased from the CDE and for the first two anniversary dates after the purchase (for a total credit of 15%), plus (2) 6% on each anniversary date thereafter for the following four years (for a total of 24%). Under pre-Act law, there was a $3.5 billion cap on the maximum annual amount of qualifying equity investments for 2010, 2011, 2012, 2013 and 2014. However, a carryover was allowed where the credit limitation for a calendar year exceeded the aggregate amount allocated for the year, but no amount could be carried over to any calendar year after 2019. New law. The Act retroactively extends the new markets tax credit through 2019. It provides up to $3.5 billion in qualified equity investments for ea...
New Law. The Act retroactively extends the Indian employment credit for two years to tax years beginning before January 1, 2017. Domestic Production Activities Deduction Rules for Puerto Rico Extended Through 2016 Under the Codes domestic production activities deduction, a taxpayer is allowed a deduction from taxable income (or adjusted gross income, in the case of an individual) that is equal to 9% of the lesser of the taxpayer's qualified production activities income (QPAI) or taxable income for the tax year. QPAI is generally domestic production gross receipts (DPGR) reduced by the sum of: (1) the costs of goods sold that are allocable to those receipts; and (2) other expenses, losses or deductions which are properly allocable to those receipts. The amount of the deduction for a tax year is limited to 50% of the wages paid by the taxpayer, and properly allocable to DPGR, during the calendar year that ends in the tax year. Wages paid to bona fide residents of Puerto Rico generally are not included in wages for purposes of computing the wage limitation amount. A taxpayer has DPGR from: (1) any sale, exchange or other disposition, or any lease, rental or license, of qualifying production property manufactured, produced, grown or extracted by the taxpayer in whole or in significant part within the U.S.; (2) any sale, exchange, etc., of qualified films produced by the taxpayer; (3) any sale, exchange or other disposition of electricity, natural gas or potable water produced by the taxpayer in the U.S.; (4) construction activities performed in the U.S.; or (5) engineering or architectural services performed in the U.S. for construction projects located in the U.S. Under pre-Act law, for the first eight years of a taxpayer beginning after December 31, 2005, and before January 1, 2015, Puerto Rico was included in the term "U.S." in determining DPGR, but only if all of the taxpayer's Puerto Rico-sourced gross receipts were taxable under the federal income tax for individuals or corporations. In computing the 50% wage limitation, the taxpayer was allowed to take into account wages paid to bona fide residents of Puerto Rico for services performed in Puerto Rico. New law. The Act retroactively extends the special domestic production activities rules for Puerto Rico for two years through 2016. Under the Act, these special rules for Puerto Rico apply for the first eleven tax years of a taxpayer beginning after December 31, 2005, and before January 1, 2017. Qualified Zone Acad...
New Law. The Act provides that the national bond volume limitation is $400 million per year for 2011 through 2016.
New Law. Effective for credits or refunds made after December 31, 2016, no credit or refund for an overpayment for a tax year will be made to a taxpayer before the 15th day of the second month following the close of that tax year (generally February 15 of the following year), if the taxpayer claimed the EITC or additional child tax credit on the tax return. Changes to 529 Plan Distribution Rules Nondeductible cash contributions can be made to a qualified tuition program (QTP or 529 plan) on behalf of a designated beneficiary. The earnings on the contributions build up tax- free, and distributions from the QTP are excludible to the extent used to pay qualified higher education expenses. For expenses paid or incurred in 2009 or 2010, qualified higher education expenses included certain expenses for the purchase of any computer technology or equipment or Internet access and related services. Any distribution from a QTP that isn't used for qualified higher education expenses is inculpable in the distributee's gross income using the annuity rules, which result in a portion of the distribution being included in gross income and a portion being excluded as a return of the amount contributed. There is a requirement to aggregate all of a beneficiary's QTPs when determining the taxable part. New law. For tax years that begin after December 31, 2014, the Act expands the definition of qualified higher education expenses for which tax-preferred distributions from 529 accounts are eligible to include the 2009/2010 computer equipment and technology rule. For distributions made after December 31, 2014, the Act modifies the 529-account rules to treat any distribution from a 529 account as coming only from that account, even if the individual making the distribution operates more than one account. And, the Act treats a refund of tuition paid with amounts distributed from a 529 account as a qualified expense if such amounts are re-contributed to a 529 account within 60 days. This provision is effective for refunds after 2014, or in the case of refunds after 2014 and before the date of enactment, for refunds re-contributed not later than 60 days after date of enactment.
