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|California Senate and Assembly Vote to Extend Property Tax Exclusion for Solar|
Jason N. Barglow, Justus J. Britt; Foley & Lardner LLP;
June 30, 2014, previously published on June 26, 2014In 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,...
|Regulation No. 9/2014|
Marina Cyrino; Tauil & Chequer Advogados in association with Mayer Brown LLP;
June 30, 2014, previously published on June 23, 2014Regulation 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).
|Normative Expository Act No. 5 of June 16, 2014|
Roberta P. Caneca, Marina Cyrino; Mayer Brown LLP;
June 30, 2014, previously published on June 24, 2014On 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...
|US 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;
June 30, 2014, previously published on June 20, 2014US 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...
|IRS 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;
June 30, 2014, previously published on June 25, 2014On 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...
|Federal Banking Regulators Issue Confirmatory Guidance on Tax Refund Ownership|
Peter J. Rivas; Jones Walker LLP;
June 27, 2014, previously published on June 19, 2014On 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...
|Supreme Court Clarifies Standard to Challenge IRS Summons|
Roland Barral, David W. Foster, Armando Gomez, Julia M. Kazaks; Skadden, Arps, Slate, Meagher & Flom LLP;
June 27, 2014, previously published on June 20, 2014On 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...
|U.S. Treasury Releases Final Rules on Tax Practitioner Written Advice, Competency and Risk Management|
Padric Kelly O'Brien; Taft Stettinius & Hollister LLP;
June 27, 2014, previously published on June 24, 2014On 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...
|New Canada-U.S. Initiative to Track Time Spent in Either Country Will Spotlight Cross-Border Tax Obligations|
Natasha Miklaucic; Borden Ladner Gervais LLP;
June 27, 2014, previously published on June 19, 2014Beginning 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...
|The Future of Gift Aid|
Graham Elliot; Withers Bergman LLP/Withers LLP;
June 26, 2014, previously published on June 24, 2014Conversations 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.