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Documents on Taxation, Banking & Financial Services

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Adobe PDFEstate, Gift and Trust Provisions in New York State 2014-15 Budget: New York State 2014-15 Budget Makes Changes to the Taxation of Estates and Gifts and the Income Taxation of Certain Trusts
Sullivan Cromwell LLP;
Legal Alert/Article
April 15, 2014, previously published on April 4, 2014
On March 31, 2014, Governor Andrew Cuomo signed into law the New York State 2014-15 Budget (the “Budget”). This memorandum describes the changes made by the Budget to the taxation of estates and gifts and the income taxation of certain trusts. We will be distributing a separate...


HTMLIRS Says Bitcoin Isn’t Money
Joel Cazares; Sheppard, Mullin, Richter & Hampton LLP;
Legal Alert/Article
April 11, 2014, previously published on April 7, 2014
On March 25, 2014 the IRS issued Notice 2014-21, which describes how the IRS will interpret existing general tax principles to apply to transactions using “virtual currencies” such as Bitcoin. This Notice is the most recent in a line of similar regulatory pronouncements issued by...


HTMLRegulatory and Tax Issues Posed By Convertible Virtual Currencies
Charles K. Kolstad, D. E. Wilson; Venable LLP;
Legal Alert/Article
April 8, 2014, previously published on April 2014
Not surprisingly, the question is how Convertible Virtual Currencies (CVCs) such as Bitcoin should be classified for tax purposes. Given the treatment of CVCs by the Financial Crimes Enforcement Network (FinCEN) in FIN-2013-G001, it is not surprising that the Internal Revenue Service also concluded...


HTMLVirtual Reality: IRS Provides Guidance on the Treatment of Bitcoin and Other Virtual Currency Transactions
Robert S. Chase, Jonathan Goldman, Daniel R.B. Nicholas, Amish M. Shah, Rich Sun; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
April 4, 2014, previously published on March 31, 2014
On March 25, 2014, the Internal Revenue Service (IRS) issued Notice 2014-21 (the Notice), which provides guidance regarding the tax treatment of Bitcoins and other virtual currency through a series of “frequently asked questions” (FAQs). The Notice provides that virtual currency is...


HTMLThe IRS: Taking the “Coin” Out of Bitcoin
Sutherland Asbill Brennan LLP;
Legal Alert/Article
March 28, 2014, previously published on March 26, 2014
The IRS released guidance on March 25 that Bitcoins and other virtual currency should be treated as property for U.S. federal income tax purposes, and not as a currency. In addition to the determination that virtual currency is property, the IRS notice made clear that some of the typical rules on...


HTMLNew Focus on Tax Sharing Agreements for Financial Institutions
David A. Froling, Jeffery E. Smith; Vorys, Sater, Seymour and Pease LLP;
Legal Alert/Article
March 20, 2014, previously published on March 14, 2014
As most bankers know, Ohio adopted a new Ohio Financial Institutions Tax (FIT), which is based on a consolidated entity formula explained below. Given the new consolidated approach to taxing financial institutions with a presence in Ohio and the bank regulatory issues that accompany any type of...


HTMLUS Treasury Releases Substantial FATCA Guidance
John L. Harrington, Jeffrey H. Koppele, Marc D. Teitelbaum; Dentons Canada LLP;
Legal Alert/Article
March 12, 2014, previously published on March 6, 2014
Continuing its implementation of the Foreign Account Tax Compliance Act (FATCA), the US Treasury Department recently released a package of proposed and temporary regulations.


Adobe PDFThe Harder They Come: An Overview of Financial Instrument and Institution Provisions in the Ways & Means 2014 Tax Reform Proposals
Mark H. Leeds; Mayer Brown LLP;
Legal Alert/Article
March 6, 2014, previously published on March 3, 2014
There are a lot of lost causes in the federal income tax arena. It certainly seems the more ambitious the plan, the less likely it will receive serious consideration. Remember the tax proposals in the Simpson-Bowles Plan? That’s OK, neither do we.


HTMLMassachusetts Governor Proposes Insurance Industry Pass-Through Tax
Andrew D. Appleby, Scott A. Booth; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
March 4, 2014, previously published on January 28, 2014
The Massachusetts Governor released his proposed fiscal year 2015 budget, which includes a tax provision that is targeted directly at the insurance industry. Currently, income earned by pass-through entities, such as partnerships, owned by licensed life or property and casualty insurers is excluded...


HTMLPennsylvania Supreme Court Deposits Bank's Uniformity Claim in the Recycling Bin
Andrew D. Appleby, Zachary T. Atkins; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
March 3, 2014, previously published on January 8, 2014
The Pennsylvania Supreme Court held that treating a merger between two in-state banks differently than a merger between an in-state bank and an out-of-state bank did not violate the Uniformity Clause of the Pennsylvania Constitution. If two in-state banks merged, Pennsylvania law formerly required...


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