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Adobe PDFPresident Obama's Fiscal Year 2016 Revenue Proposals: Proposals Relating to International Taxation
Eric M. Lopata, Andrew S. Mason, Assaf Y. Prussak, Andrew P. Solomon, Davis J. Wang; Sullivan & Cromwell LLP;
Legal Alert/Article
March 31, 2015, previously published on February 17, 2015
On February 2, 2015, the Obama Administration (the “Administration”) released the General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (commonly known as the “Green Book”). Although the Green Book does not include proposed statutory language,...

 

HTMLChamberlain Hrdlicka Attorneys Author 2015 Version of Pennsylvania Tax Handbook
Chamberlain Hrdlicka White Williams Aughtry;
Legal Alert/Article
March 30, 2015, previously published on March 23, 2015
With tax time on the horizon, national law firm Chamberlain, Hrdlicka, White, Williams & Aughtry is pleased to announce that attorneys Stewart M. Weintraub, Jennifer Weidler Karpchuk and Shari J. Odenheimer have authored the 2015 version of the Pennsylvania Tax Handbook.

 

HTMLTax Evasion: Voluntary Declarations at Record High
Michael Rainer, Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
March 30, 2015, previously published on March 30, 2015
According to a survey by the “Welt am Sonntag”, the authorities have already received more than 35,000 voluntary declarations for tax evasion in this year.

 

HTMLFrench Tax Update - Noteworthy Tax Courts Decisions and Draft Macron Law
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
March 30, 2015, previously published on March 2015
The present French Tax Update will focus on (i) certain noteworthy tax courts decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the so-called projet de loi Macron (Draft Macron Law) adopted by the Assemblée Nationale in February 2015 and now discussed by...

 

HTMLIRS Ruling Permits Inclusion of “Friendly PCs” in Consolidated Federal Income Tax Returns
Theresa C. Carnegie, Ryan J. Cuthbertson, Carrie A. Roll, Jonathan R. Talansky; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
Legal Alert/Article
March 30, 2015, previously published on February 13, 2015
On December 19, 2014, the Internal Revenue Service (“IRS”) issued a private letter ruling (the “Ruling”) allowing corporations that manage physician practices through a so-called “friendly physician” arrangement to treat the physician practices as members of the...

 

HTMLConstitutional Challenges to Ohio CAT's Bright-Line Presence Nexus Test Advance
Madison J. Barnett, Stephanie T. Do; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
March 30, 2015, previously published on March 27, 2015
The Ohio Board of Tax Appeals determined that two out-of-state online retailers with no physical presence in Ohio were subject to Ohio’s Commercial Activity Tax (CAT). The Board, declining to rule on the taxpayers’ constitutional arguments, found that the online retailers met...

 

HTMLProtecting Your Hospital's Tax-Exempt Status: Compliance with the Affordable Care Act and Final IRS Section 501(r) Regulations
Gerald M. Griffith, Catherine E. Livingston; Jones Day;
Legal Alert/Article
March 30, 2015, previously published on March 2015
The Patient Protection and Affordable Care Act (the "Affordable Care Act") imposes four new requirements that Section 501(c)(3) "hospital organizations" operating "hospital facilities" must meet to keep their tax-exempt status.

 

Adobe PDFForeign Fund Was Engaged in a Trade or Business in the United States as a Result of Lending and Underwriting Activities
Jeffrey D. Hochberg, Donald L. Korb, Eric M. Lopata, Andrew P. Solomon, David C. Spitzer; Sullivan & Cromwell LLP;
Legal Alert/Article
March 27, 2015, previously published on January 26, 2015
On January 2, 2015, the Internal Revenue Service (the “IRS”) released Advice Memorandum 201501013 (the “Advice Memorandum”) from the Office of Chief Counsel. The Advice Memorandum concludes that a partnership was engaged in a U.S. trade or business through lending and...

 

Adobe PDFFrench Tax Law: Landmark Court Decision Concerning the Non-Cooperative States Regime - The French Constitutional Court Has Ruled That the Non-Cooperative States Regime Must Include an Exemption for Non-Abusive Transactions
Gauthier Blanluet, Marie-Aimée Delaisi, Nicolas de Boynes; Sullivan & Cromwell LLP;
Legal Alert/Article
March 27, 2015, previously published on January 26, 2015
At the end of 2009, France enacted a regime applicable to transactions with non-EU Member States that do not comply with international standards on exchange of information (Non-cooperative States and Territories or “NCSTs”). The list of NCSTs, initially derived from the OECD...

 

Adobe PDFPresident Obama’s Fiscal Year 2016 Revenue Proposals: Proposals Relating to Taxation of Offshore Profits of U.S. Corporations
Ronald E. Creamer, Andrew S. Mason, Davis J. Wang; Sullivan & Cromwell LLP;
Legal Alert/Article
March 27, 2015, previously published on February 2, 2015
On February 2, 2015, the Obama Administration (the “Administration”) released the General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (commonly known as the “Green Book”), which contains significant detail about the fiscal year 2016 revenue...

 


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