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|Limited Partners of Investment Managers may be Subject to Self-Employment Taxes|
Donald-Bruce Abrams, Charles R. Bogle, Anthony J. Carbone, Thomas Gray; Bingham McCutchen LLP;
September 25, 2014, previously published on September 15, 2014On September 5, 2014, the Internal Revenue Service (“IRS”) issued Chief Counsel Advice 201436049 (the “CCA”), concluding that members of an investment manager were subject to self-employment (“SE”) taxes with respect to their earnings from the investment manager....
|Treasury Department and IRS Issue Long-Awaited Inversion Guidance|
Lester W. Droller, Andrew M. Eisenberg, Andrew M. Levine, Robert A. Profusek, Raymond J. Wiacek; Jones Day;
September 25, 2014, previously published on September 2014On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets forth rules that are generally effective for acquisitions completed on or after September 22, 2014, and will be included in regulations that will be...
|The New Deal: Hedge Fund Management Fees Are Subject to Social Security Taxes|
Mark H. Leeds; Mayer Brown LLP;
September 25, 2014, previously published on September 23, 2014It’s probably fair to speculate that there were significant numbers of tax aficionados (including the author of this article) among the audience for Ken Burns’ recent public television extravaganza on the Roosevelt dynasty. Unfortunately for this segment of the audience, the...
|Senator Wyden Renews Push for Tax Extenders|
Sutherland Asbill Brennan LLP;
September 25, 2014, previously published on September 18, 2014The Congressional tax agenda for the end of 2014 is now clear: tax extenders and inversions. Even as inversions dominate the news, Senate Finance Committee Chairman Ron Wyden (D-Ore.) is continuing his push to pass legislation which extends expired tax provisions. On September 15, Senator Wyden...
|Skandia: Intra-Company Supplies Treated as Taxable Transactions for VAT Purposes by the Court of Justice of the European Union|
Adam Blakemore, Catherine Richardson; Cadwalader, Wickersham & Taft LLP;
September 25, 2014, previously published on September 4, 2014On 17 September 2104, the Court of Justice of the European Union (the “CJEU”) gave its preliminary ruling in the case of Skandia America Corporation USA, Sweden Branch v Skatterverket (C-7/13) (“Skandia”). The decision of the CJEU has been awaited with interest throughout...
|M&A Update: Treasury Announces New Anti-Inversion Rules|
Cadwalader Wickersham Taft LLP;
September 25, 2014, previously published on September 23, 2014On September 22, 2014, the Treasury Department announced its intent to issue new regulations that will reduce the tax benefits available after an inversion and may make it more difficult for some U.S. companies to invert (the “Notice”). The Notice does not require congressional action...
|Draft of General Anti-Tax Avoidance Clause|
Karina Furga-Dabrowska, Rafal Mikulski, Cezary Przygodzki; Dentons Canada LLP;
September 23, 2014, previously published on September 15, 2014On September 10, 2014 the Council of Ministers announced a draft amendment to the Tax Ordinance regarding the “general anti-tax avoidance clause.”
|OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns|
J. Clark Armitage, Peter A. Barnes, Elan P. Keller, Neal M. Kochman, Patricia Gimbel Lewis; Caplin & Drysdale, Chartered;
September 23, 2014, previously published on September 23, 2014On September 16, 2014, the Organization for Economic Cooperation and Development (OECD) released its 2014 deliverables on the Base Erosion and Profit-Shifting (BEPS) project. The BEPS project, an ambitious and wide-ranging effort by the OECD’s Centre for Tax Policy and Administration (CPTA),...
|Recent Developments Pertaining to Ohio Tax Foreclosures|
Benjamin Hoen; Weltman, Weinberg & Reis Co., L.P.A.;
September 23, 2014, previously published on September 9, 2014 There have been several recent developments in Ohio concerning Tax Foreclosures. First, on September 2, 2014, the Ohio Supreme Court issued a decision clarifying a lien holder's standing to redeem properties from tax foreclosure, by paying the taxes prior to the confirmation of the sale. Second,...
|Including License Payments in the Customs Value of Good|
Dzhangar Dzhalchinov; Dentons Canada LLP;
September 23, 2014, previously published on September 17, 2014Issues relating to customs value have been a common source of questions since work began on legislation. With the customs authorities paying particular attention to whether companies are performing their obligations to pay license fees to intellectual property rights holders, the subject is...