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HTMLUS Treasury May Require Gain Recognition on Certain Transfers of Appreciated Property to Partnerships on or After 6 August 2015
Kristin Konschnik, Mitchell R. Kops, Eric Roose; Withers Bergman LLP;
Legal Alert/Article
August 20, 2015, previously published on August 18, 2015
On 6 August 2015, the US Treasury Department issued Notice 2015-54 outlining its intent to issue regulations under US Internal Revenue Code Section 721(c) to ensure pre-existing ('built-in') gain in assets that are contributed to a partnership is recognized by the contributing partner under certain...

 

HTMLNew Law Requires Consistent Tax Basis Reporting
David J. DelFiandra; Leech Tishman;
Legal Alert/Article
August 20, 2015, previously published on August 20, 2015
The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 was signed into law on July 31, 2015.

 

HTMLTax Hedging Policies for Commodities Companies - How to Avoid an Expensive Foot Fault
John Kaufmann; Greenberg Traurig, LLP;
Legal Alert/Article
August 20, 2015, previously published on August 19, 2015
Unless they are in the business of placing bets on the price of oil or gold, commodities companies have to hedge price risk. Miners, drillers, pipeline operators, refiners - while commodity prices may affect their business, these taxpayers are in the business of providing a service, rather than...

 

HTMLTreasury Issues Notice of Upcoming Regulations Pertaining to Transfers of Certain Property to Partnerships With Foreign Related Partners
Kristin Konschnik, Mitchell R. Kops, Eric Roose; Withers Bergman LLP;
Legal Alert/Article
August 20, 2015, previously published on August 18, 2015
On 6 August 2015, the US Department of the Treasury issued Notice 2015-54 (the 'Notice') outlining its intent to issue regulations under Internal Revenue Code ('IRC') Section 721(c). These new regulations are designed to ensure that when a US person transfers certain appreciated property to a...

 

HTMLQPC on the French Reit-Like Regime
Nicolas Andre, Siamak Mostafavi; Jones Day;
Legal Alert/Article
August 19, 2015, previously published on August 2015
On the conformity to the French Constitution of the provisions of the French tax code relating to the specific REIT-like tax regime (Société d'Investissements Immobiliers Cotée, SIIC) set forth under Articles 208 C et seq of the French tax code (FTC), the Conseil...

 

HTMLTax Hedging Policies for Insurance Companies - How to Avoid an Expensive Foot Fault
John Kaufmann; Greenberg Traurig, LLP;
Legal Alert/Article
August 19, 2015, previously published on August 19, 2015
Insurance companies are in the business of assuming risk for a fee. Fire, casualty, medical expenses, catastrophic weather events, interest rate fluctuations, portfolio crashes - all of these may be insured. In order to insulate themselves from the risks that they assume, insurers buy protection at...

 

HTMLScope of the Former 40 Percent Tax Basis Relief on Dividends
Nicolas Andre, Siamak Mostafavi; Jones Day;
Legal Alert/Article
August 19, 2015, previously published on August 2015
Unlike the aforementioned QPC rulings, the Conseil Constitutionnel did not find the provisions of the FTC relating to the taxation of dividends received by individual shareholders fully compliant with the French Constitution.

 

HTMLIntragroup Reorganization and Abuse of Law Theory
Nicolas Andre, Nicolas Andre, Siamak Mostafavi, Siamak Mostafavi; Jones Day;
Legal Alert/Article
August 19, 2015, previously published on August 2015
In the context of the intragroup reorganization of a multinational automobile manufacturer, the Conseil d'Etat recently restated its position in favor of the freedom of choice (CE, July 8, 2015, n°365850).

 

HTMLCalifornia Locally Assessed Property Tax - 2015 Assessment Appeals
Marvin A. Kirsner, Norman H. Lane, Bradley R. Marsh, Charles A. Simmons; Greenberg Traurig, LLP;
Legal Alert/Article
August 19, 2015, previously published on August 18, 2015
County Assessors across California believe that the property located in their counties is worth substantially more this year than it was last year. Each Assessor is required to prepare an annual assessment roll consisting of all taxable property in their county. In many counties, roll values...

 

HTMLLawsuit Challenges Constitutionality of Recent Louisiana Business Utilities Sales Tax
Andre B. Burvant, Justin B. Stone; Jones Walker LLP;
Legal Alert/Article
August 19, 2015, previously published on August 18, 2015
House Concurrent Resolution No. 8 ("HCR 8") suspends certain tax exemptions on "business utilities" for the tax periods beginning on or after July 1, 2015 through August 5, 2016. Pursuant to HCR 8, businesses will pay a one percent (1%) sales and use tax on their purchases of...

 


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