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HTMLNew Regulations Intended to Encourage Consolidation
Stephen J. Fyfe, Daniel Lang; Borden Ladner Gervais LLP;
Legal Alert/Article
June 23, 2016, previously published on June 13, 2016
The Ministry of Finance ("MOF") published two regulations on April 25, 2016, implementing the changes described in the April 2015 Ontario Budget. The new regulations are intended to encourage the consolidation of the LDC sector by reducing, and in some cases eliminating significant tax...

 

HTMLMississippi Tax Bulletin - April 2016: Mississippi Legislature Passes Significant Tax Relief
Alveno N. Castilla, J. Paul Varner; Butler Snow LLP;
Legal Alert/Article
June 21, 2016, previously published on May 6, 2016
On April 18, 2016, the Mississippi Legislature passed Senate Bill 2858 and enacted the “Taxpayer Pay Raise Act of 2016.” Lieutenant Governor Tate Reeves describes the Act as the largest tax relief package in Mississippi history. The changes made by the Act are estimated to save...

 

HTMLDon’t be Phased by Annuity Treatment: Taxation of Distributions During Phased Retirement
Brenna M. Clark, Adam B. Cohen, Brittany Edwards-Franklin, Thomas A. Gick, W. Mark Smith; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
June 21, 2016, previously published on June 21, 2016
On June 10, the Internal Revenue Service (IRS) issued Notice 2016-39 in response to inquiries regarding the appropriate tax treatment under section 72 of the Internal Revenue Code (the Code) for payments received by an employee from a qualified defined benefit plan during phased retirement. For...

 

HTMLNYC Tax Appeals Tribunal Determines HMO Subject to General Corporation Tax
Andrew D. Appleby; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
June 21, 2016, previously published on June 20, 2016
The New York City Tax Appeals Tribunal reversed an administrative law judge (ALJ) and determined that a health maintenance organization (HMO) was subject to the New York City general corporation tax.

 

HTMLPlanning for the $5-$10 Million Couple: Portability or Credit Shelter?
Sloane Jumper Hankins, Samantha R. Moore; Butler Snow LLP;
Legal Alert/Article
June 20, 2016, previously published on May 17, 2016
In 2009, each individual had a $3.5 million estate tax exemption. If a married individual had assets over $3.5 million, without careful planning, those assets in excess of $3.5 million would fall subject to a 45% estate tax. Careful planning often included retitling assets between spouses and...

 

HTMLCommon Reporting Standard: HMRC Guidance for Charities Released
Alana Petraske; Schnader Harrison Segal Lewis LLP;
Legal Alert/Article
June 20, 2016, previously published on June 8, 2016
As discussed in our earlier briefings, the Common Reporting Standard (CRS) is designed to combat international tax evasion by allowing countries to swap information on each other's tax payers. This is achieved by requiring banks and other 'Financial Institutions' to collect data on 'Account...

 

HTMLWCO Technical Committee on Customs Valuation Sanctions Use of Transfer Pricing Studies
Darrel H. Pearson; Bennett Jones LLP;
Legal Alert/Article
June 16, 2016, previously published on May 9, 2016
To support the use of transfer pricing studies as an aid in establishing that prices paid or payable are not influenced by the relationship between vendor and purchaser, the World Customs Organization (WCO) has sought for many years to reconcile differences between transfer prices for tax purposes...

 

HTMLOttawa Acknowledges Unintended Threat: Rescinds New Tax Rule on Spousal Trusts
Margaret E. Rintoul; Blaney McMurtry LLP;
Legal Alert/Article
June 16, 2016, previously published on June 1, 2016
The federal government has rescinded a new tax rule that contained unintended, potentially unfair implications for stepchildren.

 

HTMLCourt of Appeals Issues Critical Decision on "Big Box" Store Property Tax Appeals
Jack L. Van Coevering; Foster, Swift, Collins & Smith, P.C.;
Legal Alert/Article
June 16, 2016, previously published on May 27, 2016
On May 26, 2016, the Court of Appeals issued a published decision in Menards Inc v City of Escanaba, --- Mich App ---; COA Dk No. 325718 (May 26, 2016), reversing the Tax Tribunal’s decision. The Court of Appeals held that when a market contains distressed sales of property, a sales...

 

HTMLBringing Light to Michigan’s “Dark Stores”
Jack L. Van Coevering; Foster, Swift, Collins & Smith, P.C.;
Legal Alert/Article
June 16, 2016, previously published on May 31, 2016
Over the last year, a number of Michigan and national newspapers have reported on the “Dark Store Theory” of valuation---a property tax minimization strategy national retailers have used to claim that their “big box” stores should be valued differently from other commercial...

 


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