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|IRS Ruling Permits Inclusion of “Friendly PCs” in Consolidated Federal Income Tax Returns|
Theresa C. Carnegie, Ryan J. Cuthbertson, Carrie A. Roll, Jonathan R. Talansky; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
March 30, 2015, previously published on February 13, 2015On December 19, 2014, the Internal Revenue Service (“IRS”) issued a private letter ruling (the “Ruling”) allowing corporations that manage physician practices through a so-called “friendly physician” arrangement to treat the physician practices as members of the...
|Protecting Your Hospital's Tax-Exempt Status: Compliance with the Affordable Care Act and Final IRS Section 501(r) Regulations|
Gerald M. Griffith, Catherine E. Livingston; Jones Day;
March 30, 2015, previously published on March 2015The Patient Protection and Affordable Care Act (the "Affordable Care Act") imposes four new requirements that Section 501(c)(3) "hospital organizations" operating "hospital facilities" must meet to keep their tax-exempt status.
|Tax Evasion: Voluntary Declarations at Record High|
Michael Rainer, Michael Rainer; GRP Rainer LLP;
March 30, 2015, previously published on March 30, 2015According to a survey by the “Welt am Sonntag”, the authorities have already received more than 35,000 voluntary declarations for tax evasion in this year.
|French Tax Update - Noteworthy Tax Courts Decisions and Draft Macron Law|
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
March 30, 2015, previously published on March 2015The present French Tax Update will focus on (i) certain noteworthy tax courts decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the so-called projet de loi Macron (Draft Macron Law) adopted by the Assemblée Nationale in February 2015 and now discussed by...
|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...