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HTMLThe Anson Decision - More (or Less) Clarity on UK Treatment of US LLCs
Kristin Konschnik, Mitchell R. Kops, Eric Roose; Withers Bergman LLP;
Legal Alert/Article
September 3, 2015, previously published on September 3, 2015
On 1 July 2015 the UK's Supreme Court issued an eagerly awaited decision about the UK tax treatment of UK-based members of US LLCs. Although the dispute related to one particular LLC formed in Delaware, the decision potentially applies far more broadly - to LLCs outside Delaware, to other types of...

 

HTMLCourt of Appeals Hears Michigan’s Compact Election Cases
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
September 3, 2015, previously published on September 3, 2015
The long saga of Michigan's Multistate Tax Compact election continued on Wednesday with oral argument before the Michigan Court of Appeals. A packed courtroom witnessed a 1.5 hour proceeding before an active three-judge panel. The arguments focused primarily on: (1) whether legislation can...

 

HTMLTexas Tax Update at a Glance
Kirk R. Lyda, Charolette F. Noel; Jones Day;
Legal Alert/Article
September 2, 2015, previously published on September 2015
It has been a fairly active first part of 2015 for Texas tax issues—legislatively, judicially, and administratively. We will provide a more thorough review in a future edition, but here are the key updates at a glance.

 

HTMLCity of Chicago's Department of Finance Issues Rulings Impacting Web Based Entertainment
Mark P. Rotatori, Meghan E. Sweeney; Jones Day;
Legal Alert/Article
September 2, 2015, previously published on September 2015
On June 9, 2015, the City of Chicago's Department of Finance issued two rulings with potential tax implications for web-based entertainment and information sources (specifically in the form of searchable databases). These rulings, titled Amusement Tax Ruling #5 ("Ruling #5") and Personal...

 

HTMLEmployment Services and Exemptions in Castle Case
Eric Norris Reynolds, Todd S. Swatsler; Jones Day;
Legal Alert/Article
September 2, 2015, previously published on September 2015
On March 9, 2015, the Ohio Board of Tax Appeals issued a decision in A.M. Castle v. Joseph W. Testa, Tax Commissioner, No. 2013-5851. At issue in the case was whether A.M. Castle's purchase of employment services—specifically truck drivers—from D.C. Transportation was subject to Ohio...

 

Adobe PDFTax Strategies for Selling Your Company
David C. Boatwright; Procopio, Cory, Hargreaves & Savitch LLP;
Legal Alert/Article
September 2, 2015, previously published on June 9, 2015
The tax consequences of an asset sale by an entity can be very different than the consequences of a sale of the outstanding equity interests in the entity, and the use of buyer equity interests as acquisition currency may produce very different tax consequences than the use of cash or other...

 

HTMLInheritance tax: Sole heir must personally occupy inherited apartment
Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
September 1, 2015, previously published on September 01, 2015
Following a ruling of the Fiscal Court of Hessen, an heir to a co-ownership share in an apartment is not spared from inheritance tax if he does not personally occupy the apartment.

 

HTMLUpdated IRS Guidance on ACA Reporting: Draft 2015 Forms and Instructions Released by IRS
Gabriel S. Marinaro; Smith Haughey Rice & Roegge, P.C.;
Legal Alert/Article
September 1, 2015, previously published on August 19, 2015
The IRS recently issued draft 2015 Forms 1094-B, 1095-B, 1094-C, and 1095-C. Along with these forms, the IRS issued draft 2015 instructions for completing these forms (which can be accessed here and here). Smith Haughey also previously issued a client alert on the 2014 final forms, which can be...

 

HTMLAmnesty, Hon! Maryland Tax Amnesty Begins September 1, 2015
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
August 31, 2015, previously published on August 31, 2015
From September 1, 2015, through October 30, 2015, the Comptroller of Maryland will administer a Tax Amnesty Program (Program) for tax periods beginning before December 31, 2014. Eligible taxpayers that participate in the Program will receive a waiver of certain civil penalties and a reduction of...

 

HTMLSenate To Take Aim At Medical Device Tax
McDonald Hopkins LLC;
Legal Alert/Article
August 28, 2015, previously published on August 28, 215
There is bipartisan support for repeal of the medical device tax. Although the House passed its repeal bill in June, hurdles still remain to get the bill across the finish line in the Senate.

 


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