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|Important Staff Appointments|
Patrikios Pavlou Associates LLC;
July 27, 2015, previously published on Summer 2015Stella Strati appointed as Cyprus National Reporter to the IBA's Taxes Committee and Georgia Onoufriou admitted to the CFA's International Business Committee.
|Supreme Court Agrees to Hear Interstate Row About Agency Liability for Aggressive Tax Collection Practices|
Ed Chansky, Jeremiah Coder, G. Michelle Ferreira, Courtney A. Hopley, Bradley R. Marsh; Greenberg Traurig, LLP;
July 24, 2015, previously published on July 16, 2015The U.S. Supreme Court granted certiorari of a Nevada Supreme Court decision that imposed tort liability against the California Franchise Tax Board for the agency’s action in conducting a tax audit. The eventual decision by the U.S. Supreme Court will give guidance on the scope of sovereign...
|Voluntary Disclosure Programmes - Private Foundations: The Problem Stated|
Giulia Cipollini, Filippo Noseda; Withers Bergman LLP;
July 24, 2015, previously published on July 15, 2015A number of jurisdictions (including the US, the UK and Italy) have launched voluntary disclosure ('VD') programmes. A substantial number of cases involve private foundations, typically legacy structures based in Liechtenstein and Panama.
|Hog Wild: In Harley-Davidson, California Court of Appeal Finds Discrimination, Affirms Nexus|
Andrew D. Appleby, Michael P. Penza; Sutherland Asbill & Brennan LLP;
July 22, 2015, previously published on July 21, 2015The California Court of Appeal held that California’s disparate treatment of intrastate and interstate unitary businesses discriminated against interstate commerce. California requires taxpayers engaged in a unitary business within and without California to calculate their taxable income...
|A Reasonable Result in Massachusetts: Related Party Interest Deductions Allowed Under the Unreasonable Exception|
Open Weaver Banks, Stephen A. Burroughs, Jonathan A. Feldman; Sutherland Asbill & Brennan LLP;
July 21, 2015, previously published on July 20, 2015In a significant taxpayer win, the Massachusetts Appellate Tax Board (ATB) held that intercompany interest payments from a wholly owned subsidiary to Massachusetts Mutual Life Insurance Company (MassMutual) were bona fide loans and were deductible for excise tax purposes. The subsidiary (HoldCo)...
|New Law Doubles the Penalties for Failure to File Correct Tax Information Returns and Provide Payee Statements|
Robert S. Chase, Paul R. Lang, Mary E. Monahan, David A. Roby, Vanessa A. Scott; Sutherland Asbill & Brennan LLP;
July 21, 2015, previously published on July 20, 2015On June 29, President Obama signed into law the Trade Preferences Extension Act of 2015. Quietly embedded in Section 806 of this new law is a provision that doubled the cap on penalties, from $1.5 million to $3 million, for failures to file correct tax information returns and provide payee...
|IRS Targets Use of Basket Option Contracts and Basket Contracts by Hedge Funds and Other Taxpayers as Tax Avoidance Transactions|
Robert S. Chase, Daniel R.B. Nicholas, David A. Roby, Rich Sun, Carol P. Tello; Sutherland Asbill & Brennan LLP;
July 16, 2015, previously published on July 15, 2015On July 8, the Internal Revenue Service (IRS) issued two notices (Notice 2015-47, 2015-30 IRB 1, and Notice 2015-48, 2015-30 IRB 1) targeting the use of Basket Option Contracts and Basket Contracts as tax avoidance transactions or possible tax avoidance transactions. Similar transactions have...
|It's Curtains for Some Lump-Sum Window Programs|
Bert Adams, Brian Barrett, Brenna M. Clark, Adam B. Cohen, Brittany Edwards-Franklin; Sutherland Asbill & Brennan LLP;
July 16, 2015, previously published on July 15, 2015On July 9, the Internal Revenue Service (IRS) released Notice 2015-49 to announce it intends to prohibit retirees who are receiving annuity payments from a defined benefit pension plan from electing a lump sum in lieu of the annuity. The IRS will prohibit these elections by amending the Treasury...
|New Guidance Regarding Basket Derivatives|
John Kaufmann; Greenberg Traurig LLP;
July 16, 2015, previously published on July 15, 2015On July 8, the Internal Revenue Service (the IRS) issued two new pieces of guidance regarding certain derivatives on baskets of assets. One is old wine in new bottles; the other is an expansion of the category of transaction under IRS scrutiny.
|Joint Ownership: No Longer Simple|
Arthur Fish; Borden Ladner Gervais LLP;
July 16, 2015, previously published on July 15, 2015Joint ownership is common, easy and cheap to set up and surprisingly complicated in practice. Ontario charges estate administration tax at the rate of 1.5% per on the date of death value of the assets in an estate. It has become increasingly common for people to try to avoid this tax by putting...