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|Only the Lonely: “Lonely” Life Insurance Companies Confront New Issues Under Proposed Debt-Equity Regulations|
Dennis L. Allen, Thomas A. Gick, Michael R. Miles, Mary E. Monahan, William R. Pauls; Sutherland Asbill & Brennan LLP;
April 29, 2016, previously published on April 28, 2016The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal income tax return with one or more domestic nonlife...
|Summary of Significant Corporate Tax Related Announcements in the 2016 Budget|
Andrew Terry; Withers Bergman LLP;
April 28, 2016, previously published on April 11, 2016There were a number of significant corporate tax related announcements in the recent budget some of which were anticipated and some of which were unexpected. We have summarised below a selection of those which we regard as most significant.
|Compliant Tax Structuring for the Russian Elite: Global Transparency and Domestic Law Changes|
Olga Boltenko; Withers Bergman LLP;
April 28, 2016, previously published on April 6, 2016The age of global tax transparency is upon us. Clients have to be prepared for the fact that their international private and corporate arrangements will not remain confidential, for one reason or another. This poses the question of what to do?
|Bills, Bills, Bills: Texas Court of Appeals Scrubs Bill Pay Service Provider Free of Sales Taxes|
Elizabeth S. Cha, Charles C. Kearns; Sutherland Asbill & Brennan LLP;
April 28, 2016, previously published on April 27, 2016In Hegar v. CheckFree Serv. Corp., a Texas Court of Appeals affirmed the trial court’s decision and held that the taxpayer’s online bill pay service was not a taxable data processing service for Texas sales tax purposes.
|Texas Comptroller Issues "Strong" Decision, Companies' Single Shared Administrator Not Sufficient to Require Unitary Combined Filing|
Evan M. Hamme, Marc A. Simonetti; Sutherland Asbill & Brennan LLP;
April 28, 2016, previously published on April 28, 2016The Texas Comptroller upheld a taxpayer’s separate Franchise Tax return filing position, rejecting an Administrative Law Judge’s finding that the taxpayer and its affiliate shared a strong centralized management structure that required a unitary combined report.
|State Tax Fallout From Federal Proposed Related-Party Debt Regulations|
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
April 27, 2016, previously published on April 26, 2016Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching effects for state income tax purposes, particularly on the...
|Italian Tax Authorities Publish Guidelines on Taxation of Inbound LBO Transactions|
Carla Calcagnile, Marco Lombardi; Jones Day;
April 27, 2016, previously published on April 2016On March 30, 2016, the Italian Tax Authorities ("ITA") issued Circular n. 6/E ("Circular") to clarify certain tax aspects of leveraged buyout and merger leveraged buyout transactions ("LBO" and "MLBO" respectively). The Circular also provides important...
|Treasury Releases Significant Temporary Anti-Inversion Regulations and Proposed Earnings Stripping Regulations|
Andrew M. Eisenberg, Edward T. (Ed) Kennedy, Scott M. Levine, Robert A. (Bob) Profusek; Jones Day;
April 26, 2016, previously published on April 2016On April 4, 2016, the U.S. Treasury Department released two significant packages of U.S. federal tax regulations. T.D. 9761 contains temporary regulations primarily addressing the anti-inversion rules under section 7874 of the Internal Revenue Code, and REG-108060-15 contains proposed anti-earnings...
|California: Regulators Seek Feedback for Possible Taxation Of Space Transportation Activities|
McDonald Hopkins LLC;
April 26, 2016, previously published on March 31, 2016Last March, the California Franchise Tax Board authorized its staff to hold interested party meetings to discuss the regulation of apportionment and allocation of income derived from space transportation activities. This includes the transportation of people or cargo into and from space.
|Quid Pro Quo: When a “Gift” is not a Gift|
Burnet R. Maybank, James P. Rourke; Nexsen Pruet, LLC;
April 26, 2016, previously published on April 8, 2016When it comes to properly documenting property and cash donations, most charities are well-versed with the IRS’ substantiation rules. But equally as important to those rules are the disclosure requirements regarding quid pro quo donations—that is, where the donor receives goods,...