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|Proposed US Treasury Regulations Attempt to Distinguish “Active” Insurance Companies from Hedge Funds|
James R. Barry, Jason S. Bazar, George W. Craven, Mark H. Leeds; Mayer Brown LLP;
May 4, 2015, previously published on April 27, 2015Offshore insurance companies can provide substantial tax benefits to their owner-insureds through current deductions for the insurance premium and, if properly structured, deferral on reserve investments. In 2003, the Internal Revenue Service (the IRS) warned that it would scrutinize...
|Inheritance Tax: Cuts for Company Heirs|
Michael Rainer, Michael Rainer; GRP Rainer LLP;
May 1, 2015, previously published on April 30, 2015Following the German Constitutional Court¿s (Bundesverfassungsgericht) ruling at the end of 2014 that inheritance tax must be partially reformed, company heirs may be faced with large cuts.
|Annova LNG Seeks County Tax Breaks For Export Terminal Project|
Sutherland Asbill Brennan LLP;
May 1, 2015, previously published on April 30, 2015The Brownsville Herald reports that Annova LNG (Annova) and the Cameron County Commissioners Court are in negotiations on whether to grant Annova’s request “for a 100-percent property tax abatement from the county as an economic development incentive” for Annova’s...
|Two-Year Preapproved Defined Contribution Plan Window is Still Open|
Christina M. Crockett; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
May 1, 2015, previously published on April 9, 2015Retirement plan vendors sponsoring defined contribution plan documents approved by the Internal Revenue Service (IRS) have begun issuing packages containing the new IRS-approved version of those documents-reflecting the Pension Protection Act and other required regulatory updates-to employers that...
|Brazilian State of Espírito Santo Application of the REPETRO Regime|
Carolina M. Bottino, Roberta P. Caneca, Celso Grisi, Ivan Tauil, Eduardo Maccari Telles; Tauil & Chequer Advogados in association with Mayer Brown LLP;
May 1, 2015, previously published on April 14, 2015The article 70, item LV, of the Espírito Santo’s Value-added Tax Regulations, as amended by the State Decree No. 3.658-R from August 26, 2014, authorizes a reduction on the tax basis of the Value-addex tax to three per cent (3%) until March 31, 2015, due in the customs clearance of...
|Electronic Messaging Services Not Subject to Colorado Sales or Use Tax as Telephone or Telegraph Service or Any Other Taxable Service|
Madison J. Barnett, Jessica L. Kerner; Sutherland Asbill & Brennan LLP;
May 1, 2015, previously published on April 30, 2015Colorado determined in two private letter rulings that a number of electronic messaging services are not subject to Colorado sales or use tax as a telephone or telegraph service or any other taxable service. The Company, which is not a regulated provider of telecommunications services, provides...
|Game On: Kansas DOR Rules Video Game Access Codes and Subscription Cards Are Not Subject to Sales Tax|
Open Weaver Banks, Charles C. Capouet; Sutherland Asbill & Brennan LLP;
May 1, 2015, previously published on April 30, 2015The Kansas Department of Revenue addressed the taxability of sales of video game access codes, subscription cards, point cards, and notional dollar value cards. Initial sales of access codes that allow customers to download video games or video game add-ons directly to the customer’s computer...
|IRS Traded in Your Chevy for a “Cadillac (ac-ac-ac-ac-ac) Tax”: Agency Issues First Guidance on the Implementation Code Section 4980I|
Patricia L. Beaty, Taylor Bracewell; Ogletree Deakins Nash Smoak Stewart P.C.;
April 30, 2015, previously published on April 22, 2015On February 23, 2015, the Internal Revenue Service (IRS) issued the first piece of guidance that discusses the excise tax, better known as the “Cadillac Tax,” imposed by Section 4980I of the Internal Revenue Code of 1986, as amended, on employers that offer high-cost health coverage....
|Canadian Budget 2015: Seeking the Comfort and Support of "New Balance"|
Jack Bernstein, Stuart Bollefer, David Malach, Louise R. Summerhill, Barbara J. Worndl; Aird & Berlis LLP;
April 30, 2015, previously published on April 21, 2015The Department of Finance (Canada) tabled its annual budget on April 21, 2015 (the “Budget 2015”). Normally released in February or early March, the Department of Finance (Canada) deferred its release until spring to give it an opportunity to take stock of the immediate and longterm...
|IRS Releases Final Regulations Clarifying Requirements under Section 162(m)|
Richard Fisch, Eric Loi, Louis S. Nunes, Kelly C. Simoneaux; Jones Walker LLP;
April 30, 2015, previously published on April 2015Section 162(m) of the Internal Revenue Code (IRC) and the regulations thereunder (Section 162(m)) subjects publicly held corporations to an annual $1 million deduction limit for compensation paid to certain covered employees. This deduction limit, however, does not apply to compensation that...