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HTMLWashington State Issues Sharp Reminder Regarding Reliance on Advice from Department of Revenue: Don't Forget to Get It in Writing!
Pilar Mata, Suzanne M. Palms; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
September 25, 2014, previously published on September 22, 2014
The Washington Department of Revenue determined that taxpayers have a right to rely on written but not oral instructions from the Department of Revenue. The taxpayer operated an Internet marketing business and sold its services to customers both inside and outside the state. In June 2011, the...

 

HTMLNew Yorkers, Order Away - Restaurant Website Operator Not Subject to Sales Tax on Fees
Timothy A. Gustafson, Jessica L. Kerner; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
September 25, 2014, previously published on September 19, 2014
The New York Department of Taxation and Finance advised a website operator, through which restaurants offer meals for sale, that it was not subject to sales tax on the fees it charged to the restaurants for services provided. The website allows approximately 5,000 restaurants in more than 27 cities...

 

HTMLSenator Wyden Renews Push for Tax Extenders
Sutherland Asbill Brennan LLP;
Legal Alert/Article
September 25, 2014, previously published on September 18, 2014
The Congressional tax agenda for the end of 2014 is now clear: tax extenders and inversions. Even as inversions dominate the news, Senate Finance Committee Chairman Ron Wyden (D-Ore.) is continuing his push to pass legislation which extends expired tax provisions. On September 15, Senator Wyden...

 

HTMLLew: Inversion Guidance Coming “Very, Very Soon,” Rather than Just in the “Very Near Future”
Sutherland Asbill Brennan LLP;
Legal Alert/Article
September 25, 2014, previously published on September 19, 2014
Anti-inversion guidance from Treasury is now a near-certainty, but when they arrive and how they will operate remains a mystery. Treasury Secretary Jacob Lew used strong language to warn corporations against inverting in a September 17th interview with Bloomberg Television. “Any company...

 

HTMLSchumer-Durbin Target Earnings Stripping
Jonathan Goldman; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
September 22, 2014, previously published on September 17, 2014
The change from summer to fall did nothing to alter the focus of the Congressional tax debate ¿ inversions. To that end, two Senators have introduced a new bill on “earnings stripping.”

 

HTMLCalifornia is in the Black
Thomas L. Sheehy; Greenberg Traurig, LLP;
Legal Alert/Article
September 22, 2014, previously published on September 16, 2014
California Governor Jerry Brown’s initial state budget was Sacramento’s first on-time budget in years, and the first “majority vote” budget in decades for the Golden State. Since June 2011, Governor Brown has signed three more on-time and balanced budgets. In fact, in...

 

HTMLDeoffshorisation' of the Russian Economy: Updated Version of the Draft Law on Controlled Foreign Company Legislation and Other Measures
Olga Boltenko, Ayshat Gaydarova; Withers Bergman LLP;
Legal Alert/Article
September 18, 2014, previously published on September 10, 2014
The Russian Ministry of Finance has published an updated version of the draft controlled foreign company rules (hereinafter - "CFC") on the 2nd of September (hereinafter - ‘the new Draft’). The previous drafts were covered in detail in our press releases of 24 March and 5...

 

HTMLHMRC's Accelerated Payment of Tax Powers Come Into Effect
Tessa Lorimer, Maurice Martin; Withers Bergman LLP;
Legal Alert/Article
September 10, 2014, previously published on September 5, 2014
In the 2013 Budget, the Government announced its intention to enable HMRC to issue notices to taxpayers to inform them that they should settle their outstanding tax liability in the event that a previously decided Tax Tribunal case has direct relevance to their dispute.

 

HTMLIRS Releases New Guidance on Beginning of Construction
John A. Eliason, Kurt R. Rempe; Foley & Lardner LLP;
Legal Alert/Article
August 27, 2014, previously published on August 22, 2014
The IRS recently released Notice 2014-46 (the Notice) which provides welcome guidance to tax equity investors and developers on the construction of wind, geothermal, biomass, landfill gas and certain hydropower and marine hydrokinetic energy projects for purposes of qualifying for the section 45...

 

HTMLState Lawmakers Not Blowing Smoke When It Comes To Taxing E-Cigarettes
McDonald Hopkins LLC;
Legal Alert/Article
August 26, 2014, previously published on August 21, 2014
The use of e-cigarettes is on the rise, and lawmakers are moving in to regulate and tax them. According to the Centers for Disease Control and Prevention, “about one in five adult smokers tried an e-cigarette between 2010 and 2011.” Most e-cigarette users claim they use them to reduce...

 


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