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HTMLProposed US Treasury Regulations Attempt to Distinguish “Active” Insurance Companies from Hedge Funds
James R. Barry, Jason S. Bazar, George W. Craven, Mark H. Leeds; Mayer Brown LLP;
Legal Alert/Article
May 4, 2015, previously published on April 27, 2015
Offshore insurance companies can provide substantial tax benefits to their owner-insureds through current deductions for the insurance premium and, if properly structured, deferral on reserve investments. In 2003, the Internal Revenue Service (the IRS) warned that it would scrutinize...

 

HTMLInheritance Tax: Cuts for Company Heirs
Michael Rainer, Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
May 1, 2015, previously published on April 30, 2015
Following the German Constitutional Court¿s (Bundesverfassungsgericht) ruling at the end of 2014 that inheritance tax must be partially reformed, company heirs may be faced with large cuts.

 

HTMLAnnova LNG Seeks County Tax Breaks For Export Terminal Project
Sutherland Asbill Brennan LLP;
Legal Alert/Article
May 1, 2015, previously published on April 30, 2015
The Brownsville Herald reports that Annova LNG (Annova) and the Cameron County Commissioners Court are in negotiations on whether to grant Annova’s request “for a 100-percent property tax abatement from the county as an economic development incentive” for Annova’s...

 

HTMLTwo-Year Preapproved Defined Contribution Plan Window is Still Open
Christina M. Crockett; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
Legal Alert/Article
May 1, 2015, previously published on April 9, 2015
Retirement plan vendors sponsoring defined contribution plan documents approved by the Internal Revenue Service (IRS) have begun issuing packages containing the new IRS-approved version of those documents-reflecting the Pension Protection Act and other required regulatory updates-to employers that...

 

HTMLBrazilian State of Espírito Santo Application of the REPETRO Regime
Carolina M. Bottino, Roberta P. Caneca, Celso Grisi, Ivan Tauil, Eduardo Maccari Telles; Tauil & Chequer Advogados in association with Mayer Brown LLP;
Legal Alert/Article
May 1, 2015, previously published on April 14, 2015
The article 70, item LV, of the Espírito Santo’s Value-added Tax Regulations, as amended by the State Decree No. 3.658-R from August 26, 2014, authorizes a reduction on the tax basis of the Value-addex tax to three per cent (3%) until March 31, 2015, due in the customs clearance of...

 

HTMLElectronic Messaging Services Not Subject to Colorado Sales or Use Tax as Telephone or Telegraph Service or Any Other Taxable Service
Madison J. Barnett, Jessica L. Kerner; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
May 1, 2015, previously published on April 30, 2015
Colorado determined in two private letter rulings that a number of electronic messaging services are not subject to Colorado sales or use tax as a telephone or telegraph service or any other taxable service. The Company, which is not a regulated provider of telecommunications services, provides...

 

HTMLGame On: Kansas DOR Rules Video Game Access Codes and Subscription Cards Are Not Subject to Sales Tax
Open Weaver Banks, Charles C. Capouet; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
May 1, 2015, previously published on April 30, 2015
The Kansas Department of Revenue addressed the taxability of sales of video game access codes, subscription cards, point cards, and notional dollar value cards. Initial sales of access codes that allow customers to download video games or video game add-ons directly to the customer’s computer...

 

HTMLIRS Traded in Your Chevy for a “Cadillac (ac-ac-ac-ac-ac) Tax”: Agency Issues First Guidance on the Implementation Code Section 4980I
Patricia L. Beaty, Taylor Bracewell; Ogletree Deakins Nash Smoak Stewart P.C.;
Legal Alert/Article
April 30, 2015, previously published on April 22, 2015
On February 23, 2015, the Internal Revenue Service (IRS) issued the first piece of guidance that discusses the excise tax, better known as the “Cadillac Tax,” imposed by Section 4980I of the Internal Revenue Code of 1986, as amended, on employers that offer high-cost health coverage....

 

Adobe PDFCanadian Budget 2015: Seeking the Comfort and Support of "New Balance"
Jack Bernstein, Stuart Bollefer, David Malach, Louise R. Summerhill, Barbara J. Worndl; Aird & Berlis LLP;
Legal Alert/Article
April 30, 2015, previously published on April 21, 2015
The Department of Finance (Canada) tabled its annual budget on April 21, 2015 (the “Budget 2015”). Normally released in February or early March, the Department of Finance (Canada) deferred its release until spring to give it an opportunity to take stock of the immediate and longterm...

 

Adobe PDFIRS Releases Final Regulations Clarifying Requirements under Section 162(m)
Richard Fisch, Eric Loi, Louis S. Nunes, Kelly C. Simoneaux; Jones Walker LLP;
Legal Alert/Article
April 30, 2015, previously published on April 2015
Section 162(m) of the Internal Revenue Code (IRC) and the regulations thereunder (Section 162(m)) subjects publicly held corporations to an annual $1 million deduction limit for compensation paid to certain covered employees. This deduction limit, however, does not apply to compensation that...

 


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