Sutherland Asbill & Brennan LLP New York, AZ Document Search Results (93)
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|Three's a Crowd: Texas Court of Appeals Denies Taxpayer's MTC Three-Factor Election|
Andrew D. Appleby, Olga Jane Goldberg; Sutherland Asbill & Brennan LLP;
August 28, 2015, previously published on August 27, 2015The Texas Court of Appeals held that a taxpayer was not entitled to elect the Multistate Tax Compact (MTC) three-factor formula because the Texas franchise (margin) tax is not an “income tax,” as defined in the MTC. Specifically, the court ruled that the franchise tax is not...
|No Alternative to Nexus: Parent's Royalty Addback Does Not Eliminate Licensing Subsidiary's New Jersey Filing Obligation|
Nicole D. Boutros, Amy Nogid; Sutherland Asbill & Brennan LLP;
August 28, 2015, previously published on August 27, 2015The New Jersey Tax Court ruled that the Division of Taxation (“Division”) properly required a foreign (non-New Jersey domesticated) corporation to file corporation business tax (“CBT”) returns reporting licensing revenue from its parent attributable to New Jersey, based on...
|SEC Issues Guidance Clarifying Anti-Retaliation Provision of Dodd-Frank Act|
Thomas R. Bundy, Patricia A. Gorham, Cynthia M. Krus, Allegra J. Lawrence-Hardy, Robert D. Owen; Sutherland Asbill & Brennan LLP;
August 12, 2015, previously published on August 11, 2015On August 4, the U.S. Securities and Exchange Commission (SEC or “the Commission”) issued guidance that further clarifies the Dodd-Frank Act’s anti-retaliation provision.1 According to the Commission, Section 21F of the Securities Exchange Act of 1934 (the Exchange Act) protects...
|The Windy City’s Taxes on Cloud Computing, Streaming Services|
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Leah Robinson; Sutherland Asbill & Brennan LLP;
August 10, 2015, previously published on August 10, 2015On August 7, the Chicago Department of Finance delayed the effective date of the imposition of the Personal Property Lease Transaction Tax (the Lease Tax) on cloud computing services from September 1, 2015, to January 1, 2016. However, the Department did not delay the effective date of the...
|CFTC and NFA Afford Relief from Certain CTA Periodic Reporting Obligations|
Brian Barrett, James M. Cain, Daphne G. Frydman, David T. McIndoe, Mark D. Sherrill; Sutherland Asbill & Brennan LLP;
August 7, 2015, previously published on August 6, 2015On July 21, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) published an exemptive letter that provides relief from periodic reporting on CFTC Form CTA-PR to commodity trading advisors (CTAs) that do not direct client...
|Out of Steam: Nuclear Power Company Loses Bid for New York Manufacturing Tax Credits|
Open Weaver Banks, Chris Mehrmann; Sutherland Asbill & Brennan LLP;
July 31, 2015, previously published on July 30, 2015A New York appellate court denied a nuclear power company’s bid for manufacturing tax credits, finding that equipment used at two power plants to produce steam and water during the electricity generation process was not used for manufacturing. The taxpayer argued that the process of creating...
|Update on NAIC and State Regulatory Activity on “Price Optimization”|
Eric A. Arnold, Thomas W. Curvin, Stephen E. Roth, Cynthia R. Shoss, Phillip E. Stano; Sutherland Asbill & Brennan LLP;
July 24, 2015, previously published on July 23, 2015Regulatory activity on price optimization appears to be coming to a head. The National Association of Insurance Commissioners (NAIC) Casualty Actuarial and Statistical (C) Task Force is continuing to gather input, with all roads leading toward a significant discussion of the issue at the upcoming...
|IRS Establishes 80% Threshold for Energy Companies to Apply When Determining Whether “Substantially All” of a Major Component Has Been Replaced|
Herbert N. Beller, Ellen McElroy, Michael D. Resnick, Meghana D. Shah, H. Karl Zeswitz; Sutherland Asbill & Brennan LLP;
July 23, 2015, previously published on July 23, 2015On July 6, the Internal Revenue Service (IRS) Large Business and International Division issued a Directive1 to IRS agents regarding how to determine when a major component pertaining to steam or electric generation property has been replaced for purposes of the tangible property regulations. Agents...
|Hog Wild: In Harley-Davidson, California Court of Appeal Finds Discrimination, Affirms Nexus|
Andrew D. Appleby, Michael P. Penza; Sutherland Asbill & Brennan LLP;
July 22, 2015, previously published on July 21, 2015The California Court of Appeal held that California’s disparate treatment of intrastate and interstate unitary businesses discriminated against interstate commerce. California requires taxpayers engaged in a unitary business within and without California to calculate their taxable income...
|Volcker Agencies Provide Seeding Period Guidance for BDCs, RICs and FPFs in New FAQ|
Brian Barrett, Steven B. Boehm, Harry S. Pangas, John Allen Zumpetta; Sutherland Asbill & Brennan LLP;
July 22, 2015, previously published on July 21, 2015On July 16, 2015, the agencies responsible for implementing the Volcker rule (Agencies) issued FAQ 16, which provides guidance on the circumstances under which a seed investment would not cause (i) a registered investment company (RIC), (ii) a business development company (BDC) that has elected to...