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|French Tax Law: Landmark Court Decision Concerning the Non-Cooperative States Regime - The French Constitutional Court Has Ruled That the Non-Cooperative States Regime Must Include an Exemption for Non-Abusive Transactions|
Gauthier Blanluet, Marie-Aimée Delaisi, Nicolas de Boynes; Sullivan & Cromwell LLP;
March 27, 2015, previously published on January 26, 2015At the end of 2009, France enacted a regime applicable to transactions with non-EU Member States that do not comply with international standards on exchange of information (Non-cooperative States and Territories or “NCSTs”). The list of NCSTs, initially derived from the OECD...
|Alabama DOR Proposes to Expand Rental Tax to Digital Transmissions and Multi-Purpose Cable Boxes|
Open Weaver Banks, Charles C. Capouet; Sutherland Asbill & Brennan LLP;
March 27, 2015, previously published on March 26, 2015The Alabama Department of Revenue has proposed an amendment to the state’s rental tax regulation. If finalized, the regulation would tax the rental of “digital transmissions,” such as “on-demand” movies, television programs, streaming video, streaming audio and other...
|US Congress Passes 1-year Retroactive "Extenders" Package|
Kathryn L. Anderson, John L. Harrington, Marc D. Teitelbaum; Dentons Canada LLP;
March 27, 2015, previously published on December 17, 2014It's been called "a terrible way to make tax policy" and "not that great a deal for families, individuals, and businesses"--and that's just by its supporters. Still, even though far from ideal, the "Tax Increase Prevention Act of 2014" is an early Christmas present for...
|French Tax Update: New China - France Double Tax Treaty, Amendment to Singapore - France Double Tax Treaty, Noteworthy Tax Courts Decisions and Administrative Publications|
Nicolas Andre, Fuli Cao, Siamak Mostafavi, Alexios Theologitis; Jones Day;
March 27, 2015, previously published on February 2015The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People's Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015, (iii) certain...
|President Obama’s Fiscal Year 2016 Revenue Proposals: Proposals Relating to Individual, Estate and Gift and Retirement Plan Taxation|
Charles T. Dowling, Jeffrey D. Hochberg, Andrew S. Mason, Zena M. Tamler, Marc Trevino; Sullivan & Cromwell LLP;
March 27, 2015, previously published on February 11, 2015On February 2, 2015, the Obama Administration released the General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (commonly known as the “Green Book”). Although the Green Book does not include proposed statutory language, the Green Book contains...
|B.C. Introduces Bill Providing Details on LNG Income Taxes|
Sutherland Asbill Brennan LLP;
March 27, 2015, previously published on March 26, 2015The British Columbia (B.C.) government has introduced Bill 26, the Liquefied Natural Gas Income Tax Amendment Act 2015, to “set out the remaining elements of a competitive LNG income tax framework.” The bill provides the LNG industry clarifying information under the Liquefied Natural...
|Foreign Fund Was Engaged in a Trade or Business in the United States as a Result of Lending and Underwriting Activities|
Jeffrey D. Hochberg, Donald L. Korb, Eric M. Lopata, Andrew P. Solomon, David C. Spitzer; Sullivan & Cromwell LLP;
March 27, 2015, previously published on January 26, 2015On January 2, 2015, the Internal Revenue Service (the “IRS”) released Advice Memorandum 201501013 (the “Advice Memorandum”) from the Office of Chief Counsel. The Advice Memorandum concludes that a partnership was engaged in a U.S. trade or business through lending and...
|President Obama’s Fiscal Year 2016 Revenue Proposals: Proposals Relating to Taxation of Offshore Profits of U.S. Corporations|
Ronald E. Creamer, Andrew S. Mason, Davis J. Wang; Sullivan & Cromwell LLP;
March 27, 2015, previously published on February 2, 2015On February 2, 2015, the Obama Administration (the “Administration”) released the General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (commonly known as the “Green Book”), which contains significant detail about the fiscal year 2016 revenue...
|M&A Update: Market Pressures, Favorable Law Spur REIT Conversions and Spinoffs|
William P. Mills, Richard M. Nugent; Cadwalader, Wickersham & Taft LLP;
March 26, 2015, previously published on March 16, 2015Urged on by activists and institutional shareholders, a large number of companies with real estate holdings pursued real estate investment trust (REIT) conversions or spinoffs in 2014. At least half a dozen companies completed REIT transactions last year, including cell tower company Crown Castle...
|House Bill 64, as Introduced, Includes Expansion of Ohio’s Sales Tax to Debt Collection Services|
Audra Taylor Funk; Weltman, Weinberg & Reis Co., L.P.A.;
March 25, 2015, previously published on March 5, 2015Ohio, like many states since the Great Recession, is looking to find a way to increase revenue while at the same time decrease small business income taxes and state income taxes for its residents. The current plan as proposed in the 2015-2016 budget includes not only an increase in the sales tax to...