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|OECD Releases First BEPS Recommendations to G20 in Accordance with Action Plan|
October 16, 2014, previously published on October 2014As a part of the OECD/G20 project to combat base erosion and profit shifting ("BEPS"), the OECD released the first set of reports and recommendations on September 16, 2014.
|Treasury Department and IRS Issue Long-Awaited Inversion Guidance|
October 16, 2014, previously published on October 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 transactions completed on or after September 22, 2014, and will be included in regulations that will be...
|3 Years Or 18 Months - How Long Is The Redemptive Period?|
Wesley M. Plaisance; Breazeale, Sachse & Wilson, L.L.P.;
October 15, 2014, previously published on October 9, 2014Most tax sale purchasers and title attorneys know that tax sale title is subject to redemption within a three (3) year peremptive period from the date of recordation. However, the Louisiana Constitution does contain one exception to this rule. In the City of New Orleans, property that is...
|State of Rio de Janeiro Decree No. 44,974/2014: Extension of Deadline for Adherence to Tax Debt Payment Program (Tax Amnesty Program)|
Marina Cyrino, Ivan Tauil; Tauil & Chequer Advogados in association with Mayer Brown LLP;
October 14, 2014, previously published on October 6, 2014 Decree No. 44,974/2014 was published in the Official Gazette on September 30, 2014. The Decree extends until November 30,2014,the deadline to enroll in the Tax Debt Payment Program for the State of Rio de Janeiro, which was established in Decree No. 44,780/2014 and ICMS Convention No. 128/2013.
|Like a Hot Knife Through Butter: The US Congress and Internal Revenue Service Pierce Straight Through Barrier Options|
Mark H. Leeds; Mayer Brown LLP;
October 14, 2014, previously published on October 7, 2014The Internal Revenue Service (IRS) has disputed the tax consequences for holders of barrier call options for at least five years. Recently, however, Congress and the IRS have sought to use the court of public opinion and the rules for accounting method changes to influence the outcome in tax audits...
|Governor Signs Off on New Tax-Increment Financing Structure|
Alfred Fraijo, Kira N. Teshima; Sheppard, Mullin, Richter & Hampton LLP;
October 10, 2014, previously published on October 7, 2014On September 29, Governor Brown signed legislation that is seen as creating a robust new financing tool which will expand the existing mechanism of Infrastructure Financing Districts (“IFDs”) and replicate some of the functions of the state’s abolished local redevelopment...
|Amended Tax Return: NRW Wants to Continue Purchasing CDs on Tax Evaders|
Michael Rainer, Michael Rainer; GRP Rainer LLP;
October 9, 2014, previously published on October 8, 2014North Rhine-Westphalia’s (NRW) Minister of Finance, Walter Borjans, announced in the Rheinischen Post Online that NRW will continue purchasing CDs with data on suspected tax evaders.
|IRS Reminds Employers Value of “Free” Parking May Be Taxable Fringe Benefit|
Vicki M. Nielsen; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
October 9, 2014, previously published on October 2, 2014A recent Information Letter issued by the Internal Revenue Service (IRS) on the taxation of employer-provided parking, although noncontroversial, serves as a useful reminder that “free” parking for employees may result in taxes for both the employee and the employer. IRS Information...
|Ohio: Air Transportation Operator is Not a Public Utility and Not Entitled to Exemption from Sales Tax|
David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
October 8, 2014, previously published on October 2, 2014The Ohio Board of Tax Appeals (Board) recently determined in Epic Aviation, LLC v. Testa (Case No. 2012-1557) that an air transportation operator’s purchases of fuel were not exempt from Ohio sales tax because such company was not using or consuming the fuel “directly in the rendition...
|Tax Evasion: Number of Amended Tax Returns Has Doubled|
Andreas P. Demetriades; Andreas P. Demetriades & Associates- Advocates,Legal and Tax Consultants - Law Firm;
October 8, 2014Cyprus: The three most popular types of International Business Companies (IBCs) operating through Cyprus: Financing, Holding and Trading Companies.