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|Liechtenstein Disclosure Facility (LDF) - HMRC Restricts Favourable Terms|
Judith Ingham, Justine Markovitz; Withers Bergman LLP;
August 27, 2014, previously published on August 22, 2014On 14 August 2014 HM Revenue & Customs (‘HMRC’) announced a number of changes to the terms of the LDF affecting the ability of certain taxpayers who are not already registered to benefit fully from the advantageous terms.
|HMRC Removes Some Advantages of Voluntary Disclosure|
Tim George, Tessa Lorimer, Maurice Martin; Withers Bergman LLP;
August 27, 2014, previously published on August 20, 2014On 14th August 2014 HMRC announced a number of significant changes to the Liechtenstein Disclosure Facility (LDF) which have removed some of the advantages available to those individuals who still have undisclosed tax liabilities to HMRC. The original purpose of the LDF when it was launched back in...
|State Lawmakers Not Blowing Smoke When It Comes To Taxing E-Cigarettes|
McDonald Hopkins LLC;
August 26, 2014, previously published on August 21, 2014The use of e-cigarettes is on the rise, and lawmakers are moving in to regulate and tax them. According to the Centers for Disease Control and Prevention, “about one in five adult smokers tried an e-cigarette between 2010 and 2011.” Most e-cigarette users claim they use them to reduce...
|Colorado: Appellate Court Finds in Favor of Natural Gas Company in Sales Tax Exemption Dispute|
McDonald Hopkins LLC;
August 26, 2014, previously published on August 21, 2014The Court of Appeals of Colorado affirmed a lower court ruling providing that pipelines and fittings located in one of Colorado’s enterprise zones, which are used to gather and deliver natural gas from a taxpayer’s wells to its’ processing facilities, qualify for Colorado’s...
|IRS Relaxes and Clarifies Renewable Energy Tax Credit Eligibility Requirements for Projects Under Construction|
Mintz Levin Cohn Ferris Glovsky Popeo P.C.;
August 25, 2014, previously published on August 12, 2014On August 8, 2014, the Internal Revenue Service (IRS) issued Notice 2014-46 in response to continued industry requests for clarification on several aspects of the renewable electricity Production Tax Credit (PTC) under section 45, or the energy Investment Tax Credit under section 48 in lieu of the...
|Funds Investing in U.S. Manufacturing Companies: Foreign Investor Considerations|
Annette De La Torre; Foley & Lardner LLP;
August 25, 2014, previously published on August 20, 2014Operators of manufacturing companies, especially those considering a sale or capital raise, should understand investors’ concerns regarding direct investment. Today, investment funds with investors and investments in multiple jurisdictions constitute a large part of the U.S. manufacturing...
|One Step Closer to the Supreme Court: The Fate of Obamacare Premium Tax Credits in the Face of the Circuit Split|
Anna L. Sweigart; Spilman Thomas & Battle, PLLC;
August 22, 2014, previously published on August 13, 2014Last month, two federal courts of appeals issued opposing decisions on whether the Patient Protection and Affordable Care Act (the “ACA”) permitted subsidies, in the form of premium tax credits, to health coverage bought through insurance Exchanges operated by the federal government. As...
|Deductibility of Settlement Payments: US First Circuit Rejects the IRS’s Interpretation of Talley and Section 162(f)|
Hayden D. Brown, Geoffrey M. Collins, Brian W. Kittle; Mayer Brown LLP;
August 22, 2014, previously published on August 18, 2014In Fresenius Medical Care Holdings, the US Court of Appeals for the First Circuit held that taxpayers can meet their burden of proving that a government settlement was compensatory—and thus deductible—with evidence beyond the settlement’s terms. Thus, if the settlement agreement...
|IRS Clarifies Production Tax Credit Qualification for Renewable and Alternative Energy Facilities|
John C. Crossley; Husch Blackwell LLP;
August 21, 2014, previously published on August 14, 2014With developers in the renewable energy industry racing to complete energy projects across the country by January 1, 2016, the Internal Revenue Service (IRS) has published additional guidance to reduce uncertainty regarding the ability of certain projects to qualify for production tax credits...
|Inheritance Tax: Are Tax Concessions for Businesses Toppling?|
Michael Rainer, Michael Rainer; GRP Rainer LLP;
August 21, 2014, previously published on August 20, 2014The German Federal Constitutional Court (Bundesverfassungsgericht) is currently dealing with inheritance and gift tax. The focus is the question of whether tax benefits for businesses are justified.