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HTMLOklahoma: District Court Invalidates Obamacare Subsidies
McDonald Hopkins LLC;
Legal Alert/Article
October 23, 2014, previously published on October 16, 2014
One of President Obama’s key initiatives, the Patient Protection and Affordable Care Act (ACA), has taken a beating since the president signed it into law on March 23, 2010.

 

HTMLOhio: The Tax Impact of House Bill 483
McDonald Hopkins LLC;
Legal Alert/Article
October 23, 2014, previously published on October 16, 2014
In 2011, in an effort to make Ohio’s government smaller, more efficient, and more effective, Gov. Kasich worked with the General Assembly to enact his fiscal year 2012-13 budget. This budget cut taxes, streamlined regulations, and reformed government.

 

HTMLVoluntary Disclosure Leading To Immunity: Planned Tightening From January 1, 2015
Michael Rainer, Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
October 22, 2014, previously published on October 21, 2014
The German government has approved a bill to tighten the rules for voluntary disclosure in the event of tax evasion. The law is expected to enter into force on January 1, 2015.

 

HTMLFourth Protocol to Canada-UK Treaty Eliminates Withholding Tax on Arm’s Length Interest, but Preserves Tax Exemption for Gains on Disposition of Shares and Interests Deriving Value from Canadian Real Property
Elaine Buzzell, Nigel P.J. Johnston; McCarthy Tétrault LLP;
Legal Alert/Article
October 22, 2014, previously published on October 15, 2014
On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of...

 

HTMLBEPS 2014 Deliverables - OECD Releases First Set of Recommendations
TJ Kang, Brian O'Neill; McCarthy Tétrault LLP;
Legal Alert/Article
October 22, 2014, previously published on October 15, 2014
Canada and other members of the Organisation for Economic Co-operation and Development (OECD) and the G-20 are engaged in a project to address “base erosion and profit shifting” (BEPS) strategies used by multinational enterprises (MNEs) and are working to achieve the goals set out in...

 

HTMLCanadian Back-to-Back Loan Proposals
Nigel P.J. Johnston, Gabrielle M.R. Richards; McCarthy Tétrault LLP;
Legal Alert/Article
October 22, 2014, previously published on October 15, 2014
The 2014 federal budget included measures (Budget Measures) intended to eliminate the use of back-to-back loans to avoid the thin capitalization rules and/or withholding tax on interest paid to non-arm’s length non-residents so as to protect the Canadian tax base from erosion by limiting the...

 

HTMLSkandia: Intra-Company Supplies Treated as Taxable Transactions for VAT Purposes by the Court of Justice of the European Union
Adam Blakemore, Catherine Richardson; Cadwalader, Wickersham & Taft LLP;
Legal Alert/Article
October 22, 2014, previously published on September 24, 2014
On 17 September 2104, the Court of Justice of the European Union (the “CJEU”) gave its preliminary ruling in the case of Skandia America Corporation USA, Sweden Branch v Skatterverket (C-7/13) (“Skandia”). The decision of the CJEU has been awaited with interest throughout...

 

HTMLIRS Warns Congress Over Tax Extenders
McDonald Hopkins LLC;
Legal Alert/Article
October 19, 2014, previously published on October 10, 2014
The Internal Revenue Service is warning Congress that decisions over renewing tax provisions that expired at the end of 2013 must be made by late November, or next year's tax-filing season could be seriously disrupted.

 

Adobe PDFVAT Groups: Potential VAT Costs for Financial Groups as ECJ Recognises Intra-Entity Supplies between US Head Office and VAT-Grouped Branch
Sullivan Cromwell LLP;
Legal Alert/Article
October 19, 2014, previously published on October 10, 2014
The European Court of Justice has decided that IT services provided by Skandia America Corporation to its Swedish branch should be recognised for VAT purposes because the Swedish branch was part of a VAT group.

 

HTMLPennsylvania: The Business Privilege Tax does not Apply to the Rental Real Estate Business
McDonald Hopkins LLC;
Legal Alert/Article
October 18, 2014, previously published on October 9, 2014
In Fish, Hrabrick and Briskin v. Township of Lower Merion, the Commonwealth Court of Pennsylvania concluded that the imposition of the business privilege tax (BPT) on the appellants’/lessors’ (Appellants) rental income, defined as gross receipts from lease transactions, violates the...

 


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