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|Only the Lonely: “Lonely” Life Insurance Companies Confront New Issues Under Proposed Debt-Equity Regulations|
Dennis L. Allen, Thomas A. Gick, Michael R. Miles, Mary E. Monahan, William R. Pauls; Sutherland Asbill & Brennan LLP;
April 29, 2016, previously published on April 28, 2016The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal income tax return with one or more domestic nonlife...
|Compliant Tax Structuring for the Russian Elite: Global Transparency and Domestic Law Changes|
Olga Boltenko; Withers Bergman LLP;
April 28, 2016, previously published on April 6, 2016The age of global tax transparency is upon us. Clients have to be prepared for the fact that their international private and corporate arrangements will not remain confidential, for one reason or another. This poses the question of what to do?
|Texas Comptroller Issues "Strong" Decision, Companies' Single Shared Administrator Not Sufficient to Require Unitary Combined Filing|
Evan M. Hamme, Marc A. Simonetti; Sutherland Asbill & Brennan LLP;
April 28, 2016, previously published on April 28, 2016The Texas Comptroller upheld a taxpayer’s separate Franchise Tax return filing position, rejecting an Administrative Law Judge’s finding that the taxpayer and its affiliate shared a strong centralized management structure that required a unitary combined report.
|Summary of Significant Corporate Tax Related Announcements in the 2016 Budget|
Andrew Terry; Withers Bergman LLP;
April 28, 2016, previously published on April 11, 2016There were a number of significant corporate tax related announcements in the recent budget some of which were anticipated and some of which were unexpected. We have summarised below a selection of those which we regard as most significant.
|Bills, Bills, Bills: Texas Court of Appeals Scrubs Bill Pay Service Provider Free of Sales Taxes|
Elizabeth S. Cha, Charles C. Kearns; Sutherland Asbill & Brennan LLP;
April 28, 2016, previously published on April 27, 2016In Hegar v. CheckFree Serv. Corp., a Texas Court of Appeals affirmed the trial court’s decision and held that the taxpayer’s online bill pay service was not a taxable data processing service for Texas sales tax purposes.
|Italian Tax Authorities Publish Guidelines on Taxation of Inbound LBO Transactions|
Carla Calcagnile, Marco Lombardi; Jones Day;
April 27, 2016, previously published on April 2016On March 30, 2016, the Italian Tax Authorities ("ITA") issued Circular n. 6/E ("Circular") to clarify certain tax aspects of leveraged buyout and merger leveraged buyout transactions ("LBO" and "MLBO" respectively). The Circular also provides important...
|State Tax Fallout From Federal Proposed Related-Party Debt Regulations|
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
April 27, 2016, previously published on April 26, 2016Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching effects for state income tax purposes, particularly on the...
|Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership|
J. Clark Armitage, Kirsten Burmester, Scott D. Michel, Michael G. Pfeifer, H. David Rosenbloom; Caplin & Drysdale, Chartered;
April 26, 2016, previously published on April 5, 2016In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners. Penalties could be significant for continued non-compliance, and...
|Appeals Procedures for Tax Court Cases|
Paul G. Topolka; Nexsen Pruet, LLC;
April 26, 2016, previously published on April 1, 2016The Internal Revenue Service (Service) on March 23, 2016, issued Revenue Procedure 2016-22 which clarifies and describes the practices for the administrative appeals process in cases docketed in the United States Tax Court (Tax Court).
|Tax Court to Exempt Orgs: Substantiate!|
James P. Rourke; Nexsen Pruet, LLC;
April 26, 2016, previously published on March 16, 2016While we’re not even three full months into 2016, the United States Tax Court already has decided two cases, which disallowed tax deductions for donors based on a tax exempt entity’s failure to properly substantiate those donations.