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HTMLMTC Uniformity Committee Prepares for UDITPA Regulations
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Marc A. Simonetti; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 29, 2014, previously published on July 29, 2014
On July 28, the Multistate Tax Commission (MTC) Uniformity Committee tabled two projects to free up resources to work on apportionment regulations in anticipation of the full Commission vote later this week that could amend several key UDITPA sourcing rules.

 

HTMLAuthorized Economic Operator: Recent Changes
Dentons Canada LLP;
Legal Alert/Article
July 29, 2014, previously published on July 9, 2014
Recent amendments to the Federal Law on Customs Regulation in the RF (as amended by Federal Law No. 115-FZ on Amendments to the Federal Law on Customs Regulation in the Russian Federation of May 5, 2014 with respect to the institution of authorized economic operator) (the "Law") have made...

 

HTMLMultistate Tax Commission Targets Summer 2015 Implementation of Transfer Pricing Effort
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 29, 2014, previously published on July 29, 2014
On July 28, the Arm’s Length Adjustment Services Advisory Group (Group) of the Multistate Tax Commission (MTC) met for the third time at the MTC Annual Conference in Albuquerque, New Mexico. The Group began this effort on June 2 and met again on June 25 in furtherance of a Summer 2015...

 

HTMLDue Diligence Review Essential For Larger Transactions
Michael Rainer, Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
July 29, 2014, previously published on July 29, 2014
In the case of larger transactions, including in particular the acquisition of companies, shares in companies or investment property such as real estate, a careful risk assessment is indispensable. This kind of due diligence review provides all the relevant information for the planned purchase.

 

HTMLModel Transaction Tax Overpayment Act Gains Traction at MTC
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Ted W. Friedman, Todd A. Lard; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 29, 2014, previously published on July 28, 2014
On July 21, the Multistate Tax Commission’s (MTC) Uniformity Committee voted unanimously to send to the MTC’s Executive Committee a draft resolution recommending that the MTC endorse a model transaction tax act which, if enacted by the states, would limit frivolous lawsuits seeking to...

 

HTMLHospital lab services may not constitute unrelated trade or business: IRS Technical Advice Memorandum
Wakaba Y. Tessier; Husch Blackwell LLP;
Legal Alert/Article
July 28, 2014, previously published on July 25, 2014
On July 11, 2014, the Internal Revenue Service (“IRS”) released a Technical Advice Memorandum (“TAM”) dated March 7, 2008, which concluded that, contrary to the general rule set forth in Revenue Ruling 85-110 (“Rev. Ruling 85-110”), a tax-exempt hospital’s...

 

HTMLA Brief Overview of 2014 Iowa Tax Law Changes
Kristy Rogers; Nyemaster Goode P.C.;
Legal Alert/Article
July 28, 2014, previously published on July 23, 2014
During the 2014 legislative session, the Iowa General Assembly passed three minor tax reforms that Governor Branstad has signed into law.

 

HTMLA Synopsis of the Cyprus Holding Company
Aquilina Demetriadi; Anastasios Antoniou LLC;
Legal Alert/Article
July 28, 2014, previously published on Summer 2014
Cyprus provides an established, stable and solid legislative framework under which Cyprus companies can be formed for intermediary or ultimate holding purposes within corporate groups, in project finance, cross-border transactions or even investment management contexts.

 

HTMLThe Prodigal Pension Plan Member
Lorraine Allard; McCarthy Tétrault LLP;
Legal Alert/Article
July 28, 2014, previously published on July 16, 2014
It’s one of those pension administration nightmares - someone of pensionable age shows up at your door claiming he was an employee 20 years ago and asks for his pension. There is some evidence of employment, but no record of a pension entitlement. As a fiduciary you cannot pay out benefits...

 

HTMLUnfair Railroad Fuel Taxation? U.S. Supreme Court Agrees to Hear CSX Transportation Case
McDonald Hopkins LLC;
Legal Alert/Article
July 26, 2014, previously published on July 24, 2014
The U.S. Supreme Court granted certiorari in Alabama Dept. of Revenue v. CSX Transportation, Inc., --- S. Ct. ---- (2014), on July 1, 2014. While the Court generally addresses the questions presented in the writ of certiorari if it decides to hear the case, the Court added a question of its own for...

 


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