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HTMLMichigan: Treasury Department Used Wrong Definition in Determining Whether a Unified Business Group Existed
McDonald Hopkins LLC;
Legal Alert/Article
May 20, 2016, previously published on April 14, 2016
In the case LaBelle Management, Inc. v. Michigan Department of Treasury, decided March 31, 2016, the Michigan Court of Appeals reversed a trial court’s conclusion that three companies made up a unified business group in accordance with the federal income tax definition of constructive...

 

HTMLOhio: Gov. Kasich “Always Looking to Cut Taxes”
McDonald Hopkins LLC;
Legal Alert/Article
May 20, 2016, previously published on April 14, 2016
When Gov. John Kasich gave his sixth state of the state speech last week, the Columbus Dispatch noticed that he offered a hopeful message, but few new ideas. The governor pointed out in his speech that “just five short years ago,” Ohio faced an $8 billion deficit, and that “our...

 

HTMLConnecticut: Lawmakers Drop Plan to Tax Yale's Endowment
McDonald Hopkins LLC;
Legal Alert/Article
May 20, 2016, previously published on April 14, 2016
In our March 31 Multistate Tax Update, we addressed a Connecticut legislation that would have taxed the endowment funds of independent institutions of higher education when the aggregate sum is $10 billion or more at the end of the taxable year. Yale, with its $25.6 billion fund, was the only...

 

HTMLPennsylvania: Philadelphia Attempts to Exclude Tax Inversion Companies from City Contracts
McDonald Hopkins LLC;
Legal Alert/Article
May 20, 2016, previously published on April 14, 2016
Philadelphia City Council president Darrell L. Clarke has introduced an ordinance that would bar the city of Philadelphia from “entering into contracts with companies that hide overseas to avoid paying U.S. taxes.” More specifically, as a prerequisite to the execution of any city...

 

HTMLOur Tax Sale Title Was Annulled - Now What?
Wesley M. Plaisance; Breazeale, Sachse & Wilson, L.L.P.;
Legal Alert/Article
May 20, 2016, previously published on March 2016
With the increasing number of tax sales being annulled across the State of Louisiana due to lack of constitutionally required pretax sale notice to record owner(s), mortgage holder(s) and/or other lien holders of record, I am frequently asked by tax sale purchasers: Who is responsible for the...

 

HTMLIs it Debt or is it Not? Proposed Treasury Regulations Would Significantly Change Debt vs. Equity Analysis
Sohail Itani, Abraham A. Reshtick; Mintz Levin Cohn Ferris Glovsky Popeo P.C.;
Legal Alert/Article
May 19, 2016, previously published on April 28, 2016
Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the “Proposed Regulations”) under Section 385 of the Internal Revenue Code. The Proposed Regulations would significantly modify the tax analysis concerning the treatment of certain related-party...

 

HTMLIRS Denies Tax-Exempt Status to Non-MSSP ACO
Gerald M. (Gerry) Griffith, Catherine E. (Cathy) Livingston; Jones Day;
Legal Alert/Article
May 18, 2016, previously published on April 2016
Earlier this month, the IRS released a denial of an exemption application for an accountable care organization ("ACO") outside of the Medicare Shared Savings Program ("MSSP") that was seeking exemption under section 501(c)(3). This is the first publicly available IRS ruling on a...

 

HTMLThe Panama Papers and the U.S. Response: New Risks for Financial Institutions, Clients and Advisors
Mark E. Matthews, Scott D. Michel, Cono R. Namorato; Caplin & Drysdale, Chartered;
Legal Alert/Article
May 18, 2016, previously published on May 18, 2016
The massive Panama Papers leak from the law firm Mossack Fonseca has exposed a variety of suspicious and possibly illegal activity and drawn the attention of tax enforcement authorities and investigators worldwide. On May 9, 2016, the International Consortium of Investigative Journalists (ICIJ),...

 

HTMLMississippi Legislature Passes Significant Tax Relief
Alveno N. Castilla, J. Paul Varner; Butler Snow LLP;
Legal Alert/Article
May 18, 2016, previously published on May 6, 2016
On April 18, 2016, the Mississippi Legislature passed Senate Bill 2858 and enacted the “Taxpayer Pay Raise Act of 2016.” Lieutenant Governor Tate Reeves describes the Act as the largest tax relief package in Mississippi history. The changes made by the Act are estimated to save...

 

HTMLDetails of the Alberta Carbon Levy Announced
Beverly Gilbert; Borden Ladner Gervais LLP;
Legal Alert/Article
May 16, 2016, previously published on April 22, 2016
The implementation of the Climate Leadership Plan by Budget 2016 includes preliminary details of a Carbon Levy that will become effective on January 1, 2017. The Carbon Levy will initially feature a $20/tonne price on carbon emissions, rising to $30/tonne effective January 1, 2018. The Carbon Levy...

 


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