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|Treasury Department and IRS Issue Long-Awaited Inversion Guidance|
Lester W. Droller, Andrew M. Eisenberg, Andrew M. Levine, Robert A. Profusek, Raymond J. Wiacek; Jones Day;
September 25, 2014, previously published on September 2014On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets forth rules that are generally effective for acquisitions completed on or after September 22, 2014, and will be included in regulations that will be...
|Anti-Inversion Notice Issued: IRS and Treasury Issue Guidance Intended to Reduce the Tax Benefits of Inversion Transactions|
Sullivan Cromwell LLP;
September 25, 2014, previously published on September 24, 2014On 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...
|Skandia: 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;
September 25, 2014, previously published on September 4, 2014On 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...
|Washington 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;
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...
|California Taxpayer Entitled to Attorney Fees after Successful Commerce Clause Challenge|
Zachary T. Atkins, Prentiss Willson; Sutherland Asbill & Brennan LLP;
September 25, 2014, previously published on September 22, 2014 A California Court of Appeal held that a taxpayer who brought a successful facial challenge against a state taxing scheme met all of the requirements for an award of attorney fees and that the trial court abused its discretion by failing to award the fees. The taxpayer, an individual, sought a...
|Draft of General Anti-Tax Avoidance Clause|
Karina Furga-Dabrowska, Rafal Mikulski, Cezary Przygodzki; Dentons Canada LLP;
September 23, 2014, previously published on September 15, 2014On September 10, 2014 the Council of Ministers announced a draft amendment to the Tax Ordinance regarding the “general anti-tax avoidance clause.”
|OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns|
J. Clark Armitage, Peter A. Barnes, Elan P. Keller, Neal M. Kochman, Patricia Gimbel Lewis; Caplin & Drysdale, Chartered;
September 23, 2014, previously published on September 23, 2014On September 16, 2014, the Organization for Economic Cooperation and Development (OECD) released its 2014 deliverables on the Base Erosion and Profit-Shifting (BEPS) project. The BEPS project, an ambitious and wide-ranging effort by the OECD’s Centre for Tax Policy and Administration (CPTA),...
|Recent Developments Pertaining to Ohio Tax Foreclosures|
Benjamin Hoen; Weltman, Weinberg & Reis Co., L.P.A.;
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,...
|Planned Amendments to Income Taxes|
Karina Furga-Dabrowska, Cezary Przygodzki, Dariusz Stolarek; Dentons Canada LLP;
September 23, 2014, previously published on September 17, 2014On 16 September 2014, the Polish President signed the Act of 29 August 2014 amending the Corporate Income Tax Act, the Personal Income Tax Act and certain other laws (Amendment). The planned date on which the Amendment would come into force, subject to certain transitional provisions, is 1 January...
|IRS Affirms Treatment of Short Sales for UBTI Purposes|
Jonathan R. Talansky; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
September 23, 2014, previously published on Sepember 12, 2014Since 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...