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HTMLSay What You Mean - A Fine Distinction in Reading v Reading
Paul Hewitt, Natasha Oakshett; Withers Bergman LLP;
Legal Alert/Article
May 15, 2015, previously published on May 12, 2015
Say what you mean, but make sure you do so correctly. Good advice for any will draftsman, especially when it comes to legal terms that may have different meanings for lay persons and for lawyers.

 

HTMLCarried-Forward Tax Losses May Be Offset Against Tax Profits Only After All Expenses have been Deducted
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
May 15, 2015, previously published on May 2015
Pursuant to the French tax code, corporation income tax is applied on the net accounting profits, as adjusted for French tax purposes. Tax losses available for carry-forward are deemed to constitute an expense for corporation income tax purposes, even though they do not constitute an expense from...

 

HTMLDeduction of Final Tax Losses
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
May 15, 2015, previously published on May 2015
On April 15, 2015, the Conseil d'Etat ruled on the French treatment of the tax losses incurred by a non-French subsidiary of a French parent.

 

HTMLInternal Revenue Service Issues Final Regulations under Internal Revenue Code Section 162(m)
Manes M. Merrit, Barry L. Salkin, Karen W. Scheffler; Olshan Frome Wolosky LLP;
Legal Alert/Article
May 15, 2015, previously published on May 2015
On March 31, 2015, the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) under Internal Revenue Code (“Code”) Section 162(m) which clarify two important operational items regarding the deductibility of certain executive...

 

HTMLFICA Tax Student Exemption Resolution: Fifth Circuit Decision About Refunds of FICA Taxes Paid by Medical Residents Stands
Jeanne Ellen Floyd, Vicki M. Nielsen; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
Legal Alert/Article
May 15, 2015, previously published on May 8, 2015
FICA taxes, which fund the Social Security program, are not levied on state employees unless a state voluntarily opts in to the program. A state opts in by executing an agreement, commonly referred to as a “section 218 agreement,” with the Social Security Administration. In section 218...

 

HTMLLatest Actions of the Polish Ministry of Finance
Karina Furga-Dabrowska, Tomasz Krasowski, Sylwia Kulczycka, Cezary Przygodzki; Dentons Canada LLP;
Legal Alert/Article
May 14, 2015, previously published on May 7, 2015
Recently the Polish Ministry of Finance has presented a new bill introducing amendments to the Tax Ordinance and proposed amendments to the income tax regulations.

 

Adobe PDFOntario Reduces Production Services and Computer Animation and Special Effects Film Tax Credits
Tara Parker, Jaclyn Seidman, Carolyn Stamegna, David Zitzerman; Goodmans LLP - Toronto;
Legal Alert/Article
May 14, 2015, previously published on April 24, 2015
On April 23, 2015, Ontario Finance Minister Charles Sousa tabled the 2015 provincial Ontario budget (the “Budget”) and announced several related amendments to the three provincial Ontario film and television tax credits.

 

HTMLNew Temporary and Proposed Regulations Offer Welcome Clarification on Application of the Embedded Loan Rule
Robert S. Chase, Taylor M. Kiessig, Nicole S. Lim, Mary E. Monahan, Amish M. Shah; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
May 14, 2015, previously published on May 13, 2015
On May 8, 2015, the Treasury Department and the Internal Revenue Service published temporary and proposed regulations under IRC §§ 446 and 956 (T.D. 9719; REG-102656-15), clarifying when nonperiodic payments made pursuant to certain notional principal contracts (NPCs), must be bifurcated,...

 

HTMLSignificant Tax Changes to Estate Trusts
MaryAnne Loney; McLennan Ross LLP;
Legal Alert/Article
May 13, 2015, previously published on January 29, 2015
Effective on January 1, 2016, there will be significant changes to the manner in which trusts created under a will are subject to income tax. As there are no grandparenting provisions these changes will also affect current wills, trusts and estates.

 

HTMLWhen Bad Things Happen To Good Plans: IRS Enhances Plan Correction Methods
Peter C. Langdon; McGrath North Mullin & Kratz, PC LLO;
Legal Alert/Article
May 13, 2015
The Employee Plans Compliance Resolution System (“EPCRS”) is a program offered by the IRS that allows plan sponsors to correct retirement plan compliance violations on a voluntary basis. Plan sponsors whose plans experience operational errors or mistakes can avail themselves of EPCRS...

 


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