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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...

 

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...

 

HTMLM&A Update: Treasury Announces New Anti-Inversion Rules
Cadwalader Wickersham Taft LLP;
Legal Alert/Article
September 25, 2014, previously published on September 23, 2014
On September 22, 2014, the Treasury Department announced its intent to issue new regulations that will reduce the tax benefits available after an inversion and may make it more difficult for some U.S. companies to invert (the “Notice”). The Notice does not require congressional action...

 

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...

 

Adobe PDFAnti-Inversion Notice Issued: IRS and Treasury Issue Guidance Intended to Reduce the Tax Benefits of Inversion Transactions
Sullivan Cromwell LLP;
Legal Alert/Article
September 25, 2014, previously published on September 24, 2014
On September 22, 2014, the Internal Revenue Service (the “IRS”) and the Treasury Department (the “Treasury”) issued Notice 2014-52 (the “Notice”) announcing that the Treasury and the IRS intend to issue regulations that will address inversion transactions and...

 

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...

 

HTMLSkandia: Intra-Company Supplies Treated as Taxable Transactions for VAT Purposes by the Court of Justice of the European Union
Adam Blakemore, Catherine Richardson; Cadwalader, Wickersham & Taft LLP;
Legal Alert/Article
September 25, 2014, previously published on September 4, 2014
On 17 September 2104, the Court of Justice of the European Union (the “CJEU”) gave its preliminary ruling in the case of Skandia America Corporation USA, Sweden Branch v Skatterverket (C-7/13) (“Skandia”). The decision of the CJEU has been awaited with interest throughout...

 

HTMLDraft of General Anti-Tax Avoidance Clause
Karina Furga-Dabrowska, Rafal Mikulski, Cezary Przygodzki; Dentons Canada LLP;
Legal Alert/Article
September 23, 2014, previously published on September 15, 2014
On September 10, 2014 the Council of Ministers announced a draft amendment to the Tax Ordinance regarding the “general anti-tax avoidance clause.”

 

HTMLRecent Developments Pertaining to Ohio Tax Foreclosures
Benjamin Hoen; Weltman, Weinberg & Reis Co., L.P.A.;
Legal Alert/Article
September 23, 2014, previously published on September 9, 2014
There have been several recent developments in Ohio concerning Tax Foreclosures. First, on September 2, 2014, the Ohio Supreme Court issued a decision clarifying a lien holder's standing to redeem properties from tax foreclosure, by paying the taxes prior to the confirmation of the sale. Second,...

 

HTMLIRS Affirms Treatment of Short Sales for UBTI Purposes
Jonathan R. Talansky; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
Legal Alert/Article
September 23, 2014, previously published on Sepember 12, 2014
Since there are many hedge funds that utilize short selling as part of their investment strategy, it is important for hedge fund investors, including tax exempt organizations, to understand the U.S. tax treatment of these transactions. Fortunately for the exempt investors, the IRS has taken a...

 


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