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|IRS Updates Beginning of Construction Guidance for Renewable Energy Tax Credits Extended by PATH Act|
Dorothy Black Franzoni, Amish M. Shah, Wes Sheumaker, Ram C. Sunkara, Thomas H. Warren; Sutherland Asbill & Brennan LLP;
May 6, 2016, previously published on May 5, 2016On May 5, 2016, the Internal Revenue Service (IRS) issued Notice 2016-31, which updates prior guidance regarding the beginning of construction requirement for IRC sections 45 and 48 renewable energy tax credits following extensions of those credits in the Protecting Americans from Tax Hikes Act of...
|Neither a Partner nor Employee Be: Treasury and the IRS Issue Regulations Clarifying the Employment Tax Treatment of Partners in Partnerships|
Reginald J. Clark, Adam B. Cohen, Michael A. Hepburn, Paul R. Lang, Daniel R. McKeithen; Sutherland Asbill & Brennan LLP;
May 6, 2016, previously published on May 5, 2016The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued temporary regulations (Regulations) clarifying the federal employment tax treatment of the owners of partnerships and other entities classified as partnerships for federal tax purposes. In general, the...
|Damages Award Limited in Nevada Case Involving Tortious Conduct by California Franchise Tax Board|
Charles C. Capouet, Jeffrey A. Friedman; Sutherland Asbill & Brennan LLP;
May 3, 2016, previously published on April 29, 2016In a 4-4 decision, the U.S. Supreme Court affirmed the Nevada courts’ exercise of jurisdiction over the California Franchise Tax Board (FTB), but held, by a majority of the justices, that the taxpayer could only receive the damages Nevada provides for suits by private citizens against Nevada...
|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...
|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.
|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?
|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.
|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.
|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...