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HTMLOECD 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;
Legal Alert/Article
September 23, 2014, previously published on September 23, 2014
On 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),...

 

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...

 

HTMLNow You See It, Now You Don’t: MTC Election Disappears in Michigan?
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
September 22, 2014, previously published on September 17, 2014
On September 11, 2014, Michigan Governor Rick Snyder signed S.B. 156, which purports to repeal the state’s adoption of the Multistate Tax Compact (the Compact) retroactive to January 1, 2008. Mich. Pub. Acts 2014, No. 282 (S.B. 156). As explained by the Senate Fiscal Agency’s Bill...

 

HTMLWhat Financial Advisers and Accountants Should Know About Expanded IRS Streamlined Filing Compliance Procedures for U.S. Taxpayers with Unreported Foreign Assets and Accounts
Bruce M. Bettigole, Maia Cogen, Joseph M. DePew, Carol P. Tello, H. Karl Zeswitz; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
September 22, 2014, previously published on September 16, 2014
The Internal Revenue Service (IRS) recently announced “major changes” to its offshore compliance programs, including the Streamlined Filing Compliance Procedures (Streamlined Procedures), the delinquent international information return submission procedures (Delinquent Submission...

 

HTMLNew York: Restaurant Internet Service Provider Is Not Subject To Sales Tax
David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
Legal Alert/Article
September 22, 2014, previously published on September 18, 2014
The New York Department of Taxation and Finance ruled in Advisory Opinion No. TSB-A-14(27) S (August 20, 2014) that an Internet service provider to restaurants is not a vendor or co-vendor on restaurant sales for New York sales tax purposes, and the service fees it charges to its clients are not...

 

HTMLTax Evasion: Return to Legality Via Amended Tax Return
Michael Rainer, Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
September 22, 2014, previously published on September, 22 2014
Tax evasion has represented a lucrative, albeit criminal, business not only for tax evaders but also some banks. An amended tax return can present a path to legality.

 

HTMLSchumer-Durbin Target Earnings Stripping
Jonathan Goldman; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
September 22, 2014, previously published on September 17, 2014
The change from summer to fall did nothing to alter the focus of the Congressional tax debate ¿ inversions. To that end, two Senators have introduced a new bill on “earnings stripping.”

 

HTMLCalifornia is in the Black
Thomas L. Sheehy; Greenberg Traurig, LLP;
Legal Alert/Article
September 22, 2014, previously published on September 16, 2014
California Governor Jerry Brown’s initial state budget was Sacramento’s first on-time budget in years, and the first “majority vote” budget in decades for the Golden State. Since June 2011, Governor Brown has signed three more on-time and balanced budgets. In fact, in...

 

HTMLKentucky: Tax Appeals Board Denies Parent Corporation a Consolidated Return
David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
Legal Alert/Article
September 22, 2014, previously published on September 18, 2014
A foreign corporation and its wholly-owned subsidiary was recently denied a consolidated Kentucky corporation income tax return, as was found in World Acceptance Corporation and World Finance Corporation Kentucky v. Finance and Administration Cabinet Department of Revenue, K13-R-18, Kentucky Board...

 

HTMLThe Cost-Only Rule Applies To FOIA Fees For Property Tax Records
Alisha Biesinger, Chrissie Peterson; Heyl, Royster, Voelker & Allen Professional Corporation;
Legal Alert/Article
September 19, 2014, previously published on September 2014
A recent Illinois appellate court decision should remind government entities that charging a fee for a FOIA request should not be assessed without due care. In Sage Information Services v. Suhr, 2014 IL App (2d) 130708, the plaintiffs requested "a copy, on CD or similar electronic media, of...

 


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