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HTMLNew Annual U.S. Tax Reporting Required for Foreign-Owned U.S. Limited Liability Companies and Other U.S. Business Entities
Jon Grouf, Miriam O. Hyman, Anastasios G. Kastrinakis, Hope P. Krebs, Andrew L. Odell; Duane Morris LLP;
Legal Alert/Article
January 17, 2017, previously published on December 15, 2016
On December 13, 2016, the U.S. Treasury Department and Internal Revenue Service issued final regulations mandating that foreign-owned U.S. limited liability companies (and other U.S. business entities) treated as disregarded entities for U.S. tax purposes must file annually Form 5472-Information...

 

HTMLCheckfree - Another Taxpayer Win on New York State Online Service Receipt Sourcing; ALJ Determination Mirrors Expedia
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
January 16, 2017, previously published on January 13, 2017
New York taxpayers received additional guidance on the important issue of whether online services constitute “service” receipts, and how those receipts should be sourced, for New York corporate franchise tax purposes.

 

HTMLCalifornia Court of Appeal Holds Doing Business ≠ Any Activity Engaged In for Pecuniary Gain
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
January 16, 2017, previously published on January 14, 2017
On January 12, 2017, the California Court of Appeal held in a published opinion that a taxpayer passively holding a 0.2 percent interest in a California-based limited liability company (CA LLC) was not “doing business” in the state for purposes of being subject to California’s...

 

HTMLIncreased Tax Reporting Requirements for Domestic Disregarded Entities Wholly Owned by Foreign Persons
Mohammad B. Pathan, Kenneth Zuckerbrot; Greenberg Traurig, LLP;
Legal Alert/Article
January 12, 2017, previously published on January 9, 2017
On Dec. 13, 2016, the U.S. Department of the Treasury issued final regulations to Internal Revenue Code (Code) sections 6038A and 7701. These regulations impact Form 5472 (Information Return of a 25 percent Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business)...

 

HTMLCRA Reviews Application of “Advantage Rules” to Investment Management Fees
Joelle Kabouchi, Craig J. Webster; Borden Ladner Gervais LLP;
Legal Alert/Article
January 12, 2017, previously published on January 4, 2017
On November 29, 2016, at a Canada Revenue Agency (“CRA”) round table hosted by the Canadian Tax Foundation, CRA representatives spoke to the application of the advantage rules to payments of management fees by the annuitant of an RRSP or RRIF or the holder of a TFSA (RRSP’s,...

 

HTMLNebraska Supreme Court Rejects Department of Revenue’s Application of The Federal “Economic Substance” and “Sham Transaction” Doctrines to Nebraska’s Special Capital Gains Exclusion
Matthew R. Ottemann; McGrath North Mullin & Kratz, PC LLO;
Legal Alert/Article
January 12, 2017, previously published on Fourth Quarter 2016
In Stewart v. Nebraska Department of Revenue, the Nebraska Supreme Court rejected the Department of Revenue’s application of the “economic substance” and “sham transaction” doctrines, which were developed under federal tax law, to Nebraska’s Special Capital Gains...

 

Adobe PDFNew Regulations Repeal Automatic Requirements for Form 1099-C Under No Payment For 36 Months Rule
Edward H. Brown, Joshua A. Ehrenfeld, James M. McCarten, Bruce A. Rawls, Allen Sullivan; Burr & Forman LLP;
Legal Alert/Article
January 12, 2017, previously published on December 2016
Last month, the IRS issued final regulations repealing its rule requiring that a Form 1099-C be filed whenever a financial institution (or certain other limited taxpayers) fails to receive payment on a debt for 36 consecutive months. Treasury Decision 9793 was issued on November 10 and accompanied...

 

HTMLConsiderations For Tax Planning In The New Political Environment
Florence M. Jao, Richard S. Kinyon, Patrick R. McCabe, April Hopkins Rox, Danielle T. Zaragoza; Shartsis Friese LLP;
Legal Alert/Article
January 12, 2017, previously published on December 21, 2016
The recent election of Donald Trump as President and a Republican-controlled Congress have raised the possibility of significant changes to the tax laws, including corporate and personal income taxes and estate, gift and generation-skipping transfer taxes. President-elect Trump’s proposals...

 

Adobe PDFAmendments to Philadelphia’s Realty Transfer Tax Will Have a Significant Impact
Kevin S. Blanton, Jonathan R. Flora; Schnader Harrison Segal & Lewis LLP;
Legal Alert/Article
January 12, 2017, previously published on December 2016
Recent amendments to Philadelphia’s realty transfer tax will likely change the way commercial real estate is bought and sold. Rather than sell the real estate directly and record a traditional deed to evidence the transaction, it is common practice to sell ownership interests in the company...

 

HTMLThe Latest Word on Subsequent Legislative History and the GAAR
Jared A. Mackey; Bennett Jones LLP;
Legal Alert/Article
January 11, 2017, previously published on November 01, 2016
Two recent decisions of the Tax Court involving the general anti-avoidance rule (GAAR), Univar Holdco Canada ULC v The Queen, 2016 TCC 159 [Univar] and Oxford Properties Group Inc v The Queen, 2016 TCC 204 [Oxford Properties], have added to the array of inconsistent and controversial case law on...

 


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