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HTMLCalifornia Senate and Assembly Vote to Extend Property Tax Exclusion for Solar
Jason N. Barglow, Justus J. Britt; Foley & Lardner LLP;
Legal Alert/Article
June 30, 2014, previously published on June 26, 2014
In furtherance of California’s commitment to renewable solar energy, the California Senate and Assembly recently passed Senate Bill 871 (SB 871) which, if signed, would extend the sunset date on the existing property tax exclusion for newly constructed solar energy systems from January 1,...

 

HTMLRegulation No. 9/2014
Marina Cyrino; Tauil & Chequer Advogados in association with Mayer Brown LLP;
Legal Alert/Article
June 30, 2014, previously published on June 23, 2014
Regulation No. 9/2014 amended Regulation No. 7/2013 to reopen until 07/31/2014 the deadline for installments and payment of tax liabilities owed to the Treasury, authorized by Articles 1 to 13 of Law 11.941/2009 (Refis).

 

HTMLNormative Expository Act No. 5 of June 16, 2014
Roberta P. Caneca, Marina Cyrino; Mayer Brown LLP;
Legal Alert/Article
June 30, 2014, previously published on June 24, 2014
On June 16, 2014, Brazilian Tax Authorities enacted Normative Expository (“ADE”) Act No. 5, which revoked the ADE No. 1/2000. The ADE No. 1/2000 provided for the application of withholding tax in Brazil to payments of service fees to overseas, regardless of the existence of a Tax Treaty...

 

HTMLUS Banking Regulators Issue Additional Guidance Regarding Tax Allocation Agreements in Holding Company Structures
Scott A. Anenberg, Hayden D. Brown, J. Paul Forrester; Mayer Brown LLP;
Legal Alert/Article
June 30, 2014, previously published on June 20, 2014
US banking regulators (the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency) have issued final joint supplemental guidance (Guidance) regarding tax allocation agreements involving holding companies and...

 

HTMLIRS Issues Favorable Private Letter Ruling to Data Center REIT
Daniel R. McKeithen, R. Robinson Plowden, David A. Roby, William E. Sheumaker; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
June 30, 2014, previously published on June 25, 2014
On June 6, 2014, the Internal Revenue Service (IRS) released Private Letter Ruling 201423011 (the PLR), confirming that income from certain data center services can constitute “rents from real property” for purposes of the real estate investment trust (REIT) rules. Although the PLR is...

 

HTMLFederal Banking Regulators Issue Confirmatory Guidance on Tax Refund Ownership
Peter J. Rivas; Jones Walker LLP;
Legal Alert/Article
June 27, 2014, previously published on June 19, 2014
On June 13, 2014, federal banking regulators issued final supplemental guidance on income tax allocation agreements involving holding companies and insured depository institutions. Regulators sought to eliminate confusion among holding companies, depository institutions and their affiliates...

 

HTMLSupreme Court Clarifies Standard to Challenge IRS Summons
Roland Barral, David W. Foster, Armando Gomez, Julia M. Kazaks; Skadden, Arps, Slate, Meagher & Flom LLP;
Legal Alert/Article
June 27, 2014, previously published on June 20, 2014
On June 19, 2014, the U.S. Supreme Court in United States v. Clarke held that a taxpayer has a right to conduct an examination of IRS officials regarding their reasons for issuing an administrative summons when the taxpayer points to specific facts or circumstances plausibly raising an inference of...

 

HTMLU.S. Treasury Releases Final Rules on Tax Practitioner Written Advice, Competency and Risk Management
Padric Kelly O'Brien; Taft Stettinius & Hollister LLP;
Legal Alert/Article
June 27, 2014, previously published on June 24, 2014
On June 12, 2014, the United States Treasury Department published long-awaited regulatory changes to Circular No. 230 regarding several key aspects of practice before the Internal Revenue Service (“IRS”). Effective immediately, many of the June 14 rules fundamentally alter the way...

 

HTMLNew Canada-U.S. Initiative to Track Time Spent in Either Country Will Spotlight Cross-Border Tax Obligations
Natasha Miklaucic; Borden Ladner Gervais LLP;
Legal Alert/Article
June 27, 2014, previously published on June 19, 2014
Beginning June 30, 2014, Canada and the U.S. will implement a new joint initiative to share information with each other about when individuals cross the Canada-U.S. border to enter and leave their respective countries. This initiative will allow both countries to accurately track the whereabouts of...

 

HTMLThe Future of Gift Aid
Graham Elliot; Withers Bergman LLP/Withers LLP;
Legal Alert/Article
June 26, 2014, previously published on June 24, 2014
Conversations are underway between the Charity Tax Group ('CTG') and HMRC in respect of a potentially major reform to the operation of the gift aid rules, particularly in connection with donations which give rise to benefits to the donor.

 


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