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Documents on Taxation, Banking & Financial Services
 

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Adobe PDFUS Congress Passes 1-year Retroactive "Extenders" Package
Kathryn L. Anderson, John L. Harrington, Marc D. Teitelbaum; Dentons Canada LLP;
Legal Alert/Article
March 27, 2015, previously published on December 17, 2014
It's been called "a terrible way to make tax policy" and "not that great a deal for families, individuals, and businesses"--and that's just by its supporters. Still, even though far from ideal, the "Tax Increase Prevention Act of 2014" is an early Christmas present for...

 

Adobe PDFForeign Fund Was Engaged in a Trade or Business in the United States as a Result of Lending and Underwriting Activities
Jeffrey D. Hochberg, Donald L. Korb, Eric M. Lopata, Andrew P. Solomon, David C. Spitzer; Sullivan & Cromwell LLP;
Legal Alert/Article
March 27, 2015, previously published on January 26, 2015
On January 2, 2015, the Internal Revenue Service (the “IRS”) released Advice Memorandum 201501013 (the “Advice Memorandum”) from the Office of Chief Counsel. The Advice Memorandum concludes that a partnership was engaged in a U.S. trade or business through lending and...

 

HTMLFinancial Institution Cannot Assign Loans Based on Activities of Third Parties, Says Massachusetts Supreme Judicial Court
Zachary Atkins, Prentiss Willson; Sutherland Asbill Brennan LLP;
Legal Alert/Article
February 26, 2015, previously published on February 25, 2015
The Massachusetts Supreme Judicial Court (SJC) refused to allow a taxpayer, a financial institution, to assign its loan portfolios based on the location of third-party loan servicing activities for purposes of calculating its financial institution excise tax property factor. The taxpayer earned...

 

HTMLBank Leumi Agreement with Department of Justice Results in Disclosure of Identities of 1,500 U.S. Account Holders
Jon Grouf, James J. Holman, Hope P. Krebs, Anthony D. Martin, Megan R. Worrell; Duane Morris LLP;
Legal Alert/Article
February 17, 2015, previously published on January 12, 2015
These developments raise many significant issues for U.S. persons with undisclosed accounts at Bank Leumi with respect to potential criminal prosecution, civil examinations and the availability of the Offshore Voluntary Disclosure Program and the Streamlined Programs for residents and nonresidents.

 

HTMLFlorida: Pre-filed Bills Propose Tax Cuts in Three Areas
David H. Godenswager, David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
Legal Alert/Article
February 13, 2015, previously published on December 11, 2014
At the end of Jan. 2014, Florida Gov. Rick Scott released his “It’s Your Money Tax Cut Budget” for fiscal year 2014-2015. As he repeated when he unveiled his budget, Gov. Scott’s tenure has focused on cutting taxes, reducing spending, and reducing debt. It is, therefore, not...

 

HTMLNew Federal Law Allows Savings Accounts for Individuals with Disabilities
Michael A. Bush; Bowles Rice LLP;
Legal Alert/Article
February 9, 2015, previously published on January 13, 2015
Effective January 1, 2015, the Achieving A Better Life Experience Act (ABLE), a new federal law, provides another tool for special needs planning.

 

HTMLIgnoring IRS Notice of Deficiency May Leave Taxpayer With No Recourse for Contesting Tax Liability
Jill Misener, David J. Moise; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 20, 2014
The US Tax Court recently held in Onyango v. Comm’r 142 T.C. 24 (2014) that a taxpayer could not contest a tax liability prior to making payment where the Internal Revenue Service (IRS) issued a valid Notice of Deficiency and the taxpayer failed to take advantage of previous opportunities to...

 

HTMLNew IRS Streamlined Filing Procedures Expands Eligibility to Us Residents and Foreign Residents
Shannon Smith Retzke; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 20, 2014
For the first time, the Internal Revenue Service (IRS) streamlined filing procedures are available to US resident taxpayers who have unreported foreign income or financial accounts. The new streamlined procedures also eliminate the risk assessment process associated with the old streamlined...

 

HTMLEurasian Economic Union
Victoria Simonova; Dentons Canada LLP;
Legal Alert/Article
November 17, 2014, previously published on October 8, 2014
On 29 May 2014, the presidents of Kazakhstan, Russia and Belarus signed an agreement (the "Treaty") in Astana on the Eurasian Economic Union (the "EaEU" or the "Union"). The Treaty will enter force on 1 January 2015. According to the Treaty, the Union is an...

 

HTMLNew Provisions Concerning Thin Capitalization in Poland
BSJP Brockhuis Jurczak Prusak Sp.k.;
Legal Alert/Article
October 31, 2014
On the 1st January 2015 the provisions regarding tax deduction of the interest paid for the loans provided by the related companies (thin capitalization) are about to change.

 


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