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Documents on Taxation, Banking & Financial Services
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|The 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;
March 6, 2014, previously published on March 3, 2014There 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.
|Massachusetts Governor Proposes Insurance Industry Pass-Through Tax|
Andrew D. Appleby, Scott A. Booth; Sutherland Asbill & Brennan LLP;
March 4, 2014, previously published on January 28, 2014The 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...
|Pennsylvania Supreme Court Deposits Bank's Uniformity Claim in the Recycling Bin|
Andrew D. Appleby, Zachary T. Atkins; Sutherland Asbill & Brennan LLP;
March 3, 2014, previously published on January 8, 2014The 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...
|Domestic Anti-Treaty-Shopping Proposals and Further Consultation Announced in Canada's Federal Budget 2014|
Jared A. Mackey, Darcy D. Moch; Bennett Jones LLP;
February 21, 2014, previously published on February 18, 2014In the Canadian Federal Budget released on February 11, 2014, the Department of Finance signaled its intention to enact a domestic treaty-shopping rule, generally allowing the Canada Revenue Agency (CRA) to deny treaty benefits when the "main purpose" of a particular transaction is to...
|OECD Releases Global Standard for Automatic Exchange of FATCA-Type Information|
James Anderson, Jonathon J. Egerton-Peters, Chris Hutley-Hurst, Timothy Simon Sanders; Skadden, Arps, Slate, Meagher & Flom (UK) LLP;
February 19, 2014, previously published on February 17, 2014As part of a push for greater transparency, the Organization for Economic Cooperation and Development (OECD) released on February 13, 2014, a Common Reporting Standard (CRS) for Automatic Exchange of Financial Account Information, as well as a model Competent Authority Agreement (CAA).
|Update of the French Financial Transactions Tax (FFTT) Guidelines|
Nicolas André, Siamak Mostafavi; Jones Day;
February 14, 2014, previously published on February 2014The French tax authorities have issued on 15 January 2014 an updated version of their guidelines in respect of the FFTT (Updated Guidelines).
|Banking Bulletin: Regulators To Mandate Amendments To Tax Allocation Agreements|
Richard L. Pearlman; Adams Reese LLP;
February 6, 2014, previously published on January 23, 2014On December 19, 2013, the Federal Reserve, OCC, and FDIC issued a Proposed Addendum to the Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure. The agencies are currently soliciting comments, but we expect the Addendum to be adopted substantially as proposed.
|IRS Issues PFIC Regulations: A New Start to an Old Beginning|
Dentons Canada LLP;
January 16, 2014, previously published on January 9, 2014On December 30, 2013, the US Treasury Department (the "IRS") published a package of proposed, temporary, and final regulations relating to Passive Foreign Investment Companies ("PFICs") and their shareholders. The most significant component of the package is its guidance on the...
|Reporting Foreign Bank Accounts|
Day Pitney LLP;
January 3, 2014, previously published on December 30, 2013U.S. taxpayers with a financial interest in or signature authority over foreign financial accounts are required to report them if the aggregate value of those accounts exceeds $10,000 at any time during the calendar year.
|Avoiding the Rules on Penalties|
Dentons Canada LLP;
December 13, 2013, previously published on December 9, 2013In recent years, the courts have expanded the basis on which they will uphold as non-penal a contractual term providing for a sum to be payable, or other sanction to apply, on breach. As well as the traditional test of whether the amount due is a genuine estimate of loss, a clause may also be...