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HTMLFlorida Issues Nexus Guidance for Reinsurers
Andrew D. Appleby, Charles C. Capouet; Eversheds Sutherland (US) LLP;
Legal Alert/Article
February 28, 2017, previously published on February 27, 2017
The Florida Department of Revenue determined that a reinsurer did not have nexus with Florida for corporate income tax purposes. The Department first asserted that an insurer or reinsurer would have nexus with Florida if it was authorized to transact business in the state.

 

HTMLTaxpayer's Data Center-Related Purchases Ruled Mostly Exempt in Utah
Zachary T. Atkins, Open Weaver Banks; Eversheds Sutherland (US) LLP;
Legal Alert/Article
February 28, 2017, previously published on February 24, 2017
The Utah State Tax Commission ruled that machinery and equipment purchased by the owner of a social networking community qualified for the state’s exemption for purchases and leases of certain property used in the operation of a web search portal.

 

HTMLWhat’s New in Real Estate - Exploring Recent Changes to the Land Transfer Tax Act in Ontario
Patrick N. Aubry; Perley-Robertson, Hill & McDougall LLP/s.r.l.;
Legal Alert/Article
February 28, 2017, previously published on January 20, 2017
On December 8, 2016, Bill 70, Building Ontario Up for Everyone Act (Budget Measures), 2016, received royal assent (the “Bill”). Amongst other things, the Bill has made several changes to the Land Transfer Tax Act, R.S.O. 1990, c. L.6 (the “Act”) in Ontario, which could...

 

HTMLU.S. Oil Imports Remain Key to $1 Trillion Border Tax Plan
Jacob Dweck; Eversheds Sutherland (US) LLP;
Legal Alert/Article
February 24, 2017, previously published on January 20, 2017
Partner Jacob Dweck is quoted in this Platts article regarding a congressional plan to overhaul the tax code, which includes a border adjustment provision to encourage exports and tax imports at 20%.

 

HTMLExpanding the Water’s Edge: Four Trends to Watch in International Issues in State Taxation
Eric J. Coffill; Eversheds Sutherland (US) LLP;
Legal Alert/Article
February 24, 2017, previously published on Spring 2017
Traditionally, mandatory worldwide combined reporting was the state corporate tax issue of most concern to companies engaged in international business. States are now moving toward a water’s-edge unitary combination method for both US and foreign-based companies.

 

HTMLGlobal Tax Transparency for Corporations
Carol P. Tello; Eversheds Sutherland (US) LLP;
Legal Alert/Article
February 24, 2017, previously published on Spring 2017
Corporations with global operations are now subject to various reporting and disclosure requirements. While know-your-customer rules and anti-money laundering reporting are not new, new requirements, like Country by Country Reports, are being imposed.

 

HTMLAlabama Tax Tribunal Determines Taxpayer Properly Deducted Dividends from REIT
Nicole D. Boutros, Eric J. Coffill; Eversheds Sutherland (US) LLP;
Legal Alert/Article
February 24, 2017, previously published on February 22, 2017
The Alabama Tax Tribunal held that a taxpayer banking corporation properly deducted dividends received from an affiliated real estate investment trust (REIT) for financial institution excise tax purposes because the REIT qualified as a “corporation.” The Tribunal rejected the Department...

 

HTMLIRS Begins to Target Management Fee Waivers on Audit
Thomas A. Cullinan, Mary E. Monahan, David A. Roby, Daniel H. Schlueter, Wes Sheumaker, Rich Sun, H. Karl Zeswitz; Eversheds Sutherland (US) LLP;
Legal Alert/Article
February 24, 2017, previously published on February 23, 2017
According to a recent BNA news report, the Internal Revenue Service (IRS) has proposed adjustments and penalties to a private fund manager related to its use of management fee waivers and transaction fee offsets. Based on the report, this is one of the first cases to arise in connection with the...

 

HTMLLB&I to Closely Scrutinize Basket Transactions
Thomas A. Cullinan, Kendall C. Jones, Taylor M. Kiessig, William R. Pauls, David A. Roby, Eric Santos, Daniel H. Schlueter, Wes Sheumaker, Rebecca M. Stork, Carol P. Tello, H. Karl Zeswitz; Eversheds Sutherland (US) LLP;
Legal Alert/Article
February 21, 2017, previously published on February 21, 2017
The Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced its first 13 issue-based campaigns on January 31, 2017. As discussed in a prior Eversheds Sutherland Legal Alert, these campaigns focus on tax issues that, in LB&I’s view, pose a substantial...

 

HTMLMississippi Moves Toward Factor Presence Nexus for Use Tax
John F. Fletcher; Jones Walker LLP;
Legal Alert/Article
February 21, 2017, previously published on January 19, 2017
Companion House and Senate bills and proposed new regulation would implement $250,000 "substantial economic presence" standard

 


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