Daily Tax Update - October 23, 2014: ECJ Advocate General Encourages Abandoning 'Marks & Spencer'

ECJ Advocate General Encourages Abandoning Marks & Spencer:  In an opinion released today, an Advocate General of the European Court of Justice encouraged the ECJ to abandon the precedent established by the 2005 Marks & Spencer judgment, which permits cross-border corporate group tax relief in certain situations.  The European Commission argues that certain UK rules on group relief make it virtually impossible in practice for group relief claims to succeed.  The non-binding opinion disagreed stating, “[t]he contested UK rules go even further than is required by European Union law.”

2015 Pension Plan Limitations Announced:  The IRS announced today the maximum amount employees can contribute to Section 401(k), Section 403(b), most Section 457 plans, and government Thrift Savings Plans will increase to $18,000 in 2015.  Additionally, the maximum amount of catch-up contribution by employees aged 50 or older will increase to $6,000.