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|IRS Proposes New U.S. Tax Reporting by Foreign-Owned U.S. Limited Liability Companies|
Duane Morris LLP;
July 22, 2016, previously published on May 18, 2016On May 5, 2016, the U.S. Treasury Department announced several actions intended to strengthen financial transparency, including the issuance of proposed regulations that significantly increase the reporting and record maintenance requirements of U.S. disregarded entities owned by foreign persons.
|Crutchfield v. Testa—Can States Tax Online Interstate Retailers Based on Their Virtual Presence?|
Patrick J. Beisell, Mark P. Rotatori, E. Kendrick (Ken) Smith; Jones Day;
July 21, 2016, previously published on May 2016On May 3, 2016, the Supreme Court of Ohio heard oral argument between Crutchfield Corporation—a major electronics retailer based in Virginia—and Ohio Tax Commissioner Joseph Testa regarding whether Ohio can tax an out-of-state company based on sales of goods to Ohio consumers over the...
|IRS Accused of Improper Targeting Based on Organizations' Political Views|
Christopher Brian Best; Weltman, Weinberg & Reis Co., L.P.A.;
July 20, 2016, previously published on June 1, 2016The United States Court of Appeals for the Sixth Circuit rendered a strong decision recently, noting that no citizen should be targeted by an executive agency based on his or her political views.1 In 2010, the Treasury Department’s Inspector General for Tax Administration (“Inspector...
|New Ohio Municipal Corporation Tax Guidelines Impact Taxpayers|
Jack W. Hinneberg; Weltman, Weinberg & Reis Co., L.P.A.;
July 20, 2016, previously published on June 1, 2016New municipal income tax guidelines mandated by the State of Ohio went into effect on January 1, 2016 and effect how municipal corporations collect taxes from taxpayers. The changes are a result of the passage of Amended Substitute House Bill 5. All tax returns and payments for tax years prior to...
|Deferred No Longer: Treasury and IRS Issue Long-Awaited 409A Guidance|
Brenna M. Clark, Adam B. Cohen, Brittany Edwards-Franklin, Michael A. Hepburn, Cristopher D. Jones; Sutherland Asbill & Brennan LLP;
July 14, 2016, previously published on July 11, 2016On June 21, the Treasury Department and the Internal Revenue Service (IRS) issued proposed Internal Revenue Code (Code) section 409A regulations, modifying existing proposed and final section 409A regulations regarding deferred compensation arrangements. The proposed regulations consist of 19...
|Washington ALJ Rules Out-of-State Insurance Provider's Marketing Subject to Business & Occupation Tax as Other Services|
Jonathan A. Feldman, Alla Raykin; Sutherland Asbill & Brennan LLP;
July 8, 2016, previously published on July 7, 2016An administrative law judge (ALJ) held that a taxpayer’s activities in Washington were not selling, soliciting or negotiating insurance in the state, but rather marketing other in-state insurance companies’ products and receiving commissions from those marketing materials. Accordingly,...
|Money for Nothing: Massachusetts Appeals Court Finds Intercompany Financing Transactions Did Not Constitute Genuine Indebtedness|
Zachary T. Atkins, Charles C. Kearns; Sutherland Asbill & Brennan LLP;
July 8, 2016, previously published on July 7, 2016The Massachusetts Appeals Court upheld an Appellate Tax Board decision disallowing interest expense on certain intercompany financing transactions because the underlying agreements did not establish an “unqualified obligation to repay.” The taxpayers, subsidiaries of a British utility,...
|Compact, But No Contract: Minnesota Supreme Court Holds Compact Did Not Create Binding Contractual Obligation|
Amy F. Nogid, Hanish S. Patel; Sutherland Asbill & Brennan LLP;
July 8, 2016, previously published on July 6, 2016The Minnesota Supreme Court held that Minnesota’s adoption of the Multistate Tax Compact (Compact) did not create a binding contractual obligation and, as a result, the state’s subsequent repeal of the Compact’s alternative apportionment election provision was not prohibited as...
|A Decent Proposal to Reform the Tax Treatment of Derivatives?|
John Kaufmann; Greenberg Traurig, LLP;
July 7, 2016, previously published on June 10, 2016At the American Bar Association midyear meeting in January of this year, two panelists who spoke about the straddle rules contained in Internal Revenue Code (Code) section 1092 were asked what they expected would happen to the straddle rules over the subsequent 10 years. One panelist said that she...
|New Rules Concerning the Correction of Errors in Assessment of Real Property Taxes Will Go Into Effect in NYC|
Glenn Newman; Greenberg Traurig, LLP;
July 7, 2016, previously published on June 14, 2016On June 16, 2016, new Rules issued by the New York City Department of Finance (the Department) regarding the correction of errors concerning the assessment of real property taxes go into effect. Title 19 of the Rules of the City of New York was amended to add a new Chapter 53 authorizing the...