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HTMLMichigan Supreme Court Approves Partial Use Tax Exemption for Transmission and Distribution Equipment
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 29, 2015, previously published on July 28, 2015
The Michigan Supreme Court held that an electric utility’s transmission and distribution equipment used for both taxable and exempt purposes qualifies for a partial sales and use tax exemption. See Detroit Edison Co. v. Dept. of Treasury, No. 148753 (Mich. July 22, 2015). This marks the...

 

HTMLNot-For-Profit Hospitals Must Meet New Burdens in Financial Assistance and Debt Collection
William Covey; Heyl, Royster, Voelker & Allen Professional Corporation;
Legal Alert/Article
July 29, 2015, previously published on Spring 2015
The Internal Revenue Service has adopted new final rules and regulations placing additional regulatory burdens on not-for-profit hospitals with regard to financial assistance and debt collection. The final rules and regulations clarify the broad provisions of the Patient Protection and Affordable...

 

HTMLMTC Nearing Completion of Model Sourcing Regulation for Services and Intangibles
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 28, 2015, previously published on July 27, 2015
The Multistate Tax Commission’s (MTC) Annual Conference and Committee Meetings are being held on July 27-30, 2015, in Spokane, Washington. On Tuesday, July 28, 2015, at approximately 1:00 pm PDT (exact time subject to change), an MTC working group will present this model market-based sourcing...

 

Adobe PDFImportant Staff Appointments
Patrikios Pavlou Associates LLC;
Presentation
July 27, 2015, previously published on Summer 2015
Stella Strati appointed as Cyprus National Reporter to the IBA's Taxes Committee and Georgia Onoufriou admitted to the CFA's International Business Committee.

 

HTMLVoluntary Disclosure Programmes - Private Foundations: The Problem Stated
Giulia Cipollini, Filippo Noseda; Withers Bergman LLP;
Legal Alert/Article
July 24, 2015, previously published on July 15, 2015
A number of jurisdictions (including the US, the UK and Italy) have launched voluntary disclosure ('VD') programmes. A substantial number of cases involve private foundations, typically legacy structures based in Liechtenstein and Panama.

 

HTMLSupreme Court Agrees to Hear Interstate Row About Agency Liability for Aggressive Tax Collection Practices
Ed Chansky, Jeremiah Coder, G. Michelle Ferreira, Courtney A. Hopley, Bradley R. Marsh; Greenberg Traurig, LLP;
Legal Alert/Article
July 24, 2015, previously published on July 16, 2015
The U.S. Supreme Court granted certiorari of a Nevada Supreme Court decision that imposed tort liability against the California Franchise Tax Board for the agency’s action in conducting a tax audit. The eventual decision by the U.S. Supreme Court will give guidance on the scope of sovereign...

 

HTMLHog Wild: In Harley-Davidson, California Court of Appeal Finds Discrimination, Affirms Nexus
Andrew D. Appleby, Michael P. Penza; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 22, 2015, previously published on July 21, 2015
The California Court of Appeal held that California’s disparate treatment of intrastate and interstate unitary businesses discriminated against interstate commerce. California requires taxpayers engaged in a unitary business within and without California to calculate their taxable income...

 

HTMLNew Law Doubles the Penalties for Failure to File Correct Tax Information Returns and Provide Payee Statements
Robert S. Chase, Paul R. Lang, Mary E. Monahan, David A. Roby, Vanessa A. Scott; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 21, 2015, previously published on July 20, 2015
On June 29, President Obama signed into law the Trade Preferences Extension Act of 2015. Quietly embedded in Section 806 of this new law is a provision that doubled the cap on penalties, from $1.5 million to $3 million, for failures to file correct tax information returns and provide payee...

 

HTMLA Reasonable Result in Massachusetts: Related Party Interest Deductions Allowed Under the Unreasonable Exception
Open Weaver Banks, Stephen A. Burroughs, Jonathan A. Feldman; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 21, 2015, previously published on July 20, 2015
In a significant taxpayer win, the Massachusetts Appellate Tax Board (ATB) held that intercompany interest payments from a wholly owned subsidiary to Massachusetts Mutual Life Insurance Company (MassMutual) were bona fide loans and were deductible for excise tax purposes. The subsidiary (HoldCo)...

 

HTMLNo Appeal From Georgia Tax Tribunal's Decision on Texas Franchise Tax
Madison J. Barnett, Jonathan A. Feldman; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 16, 2015, previously published on July 15, 2015
Eight months ago, the Georgia Tax Tribunal held in Rosenberg that the Texas franchise tax (TFT) is a tax “on or measured by income” that qualifies for the pass-through entity owner’s subtraction modification available to individual Georgia residents (See prior coverage)....

 


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