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|Discover the Tax-Saving Secrets of Combining Summer Business and Personal Vacation Travel|
Duane Morris LLP;
July 22, 2016, previously published on July 12, 2016Summer is upon us, and you may be considering combining a business trip with vacation plans. Although business is business and pleasure is pleasure, the tax code does not always adhere to absolutes or logic. With a little planning, improved tax deductions may be available for out-of-town...
|IRS Proposes New U.S. Tax Reporting by Foreign-Owned U.S. Limited Liability Companies|
Duane Morris LLP;
July 22, 2016, previously published on May 18, 2016On May 5, 2016, the U.S. Treasury Department announced several actions intended to strengthen financial transparency, including the issuance of proposed regulations that significantly increase the reporting and record maintenance requirements of U.S. disregarded entities owned by foreign persons.
|Chicago Extends Voluntary Disclosure Deadline for Non-Possessory Computer Leases to June 30, 2016|
Duane Morris LLP;
July 22, 2016, previously published on May 31, 2016The City of Chicago Department of Finance (“the Department”) has extended its deadline to obtain a voluntary disclosure agreement for tax liabilities related to non-possessory computer leases to June 30, 2016. This specifically includes cloud-based services, where a charge is made to a...
|Crutchfield v. Testa—Can States Tax Online Interstate Retailers Based on Their Virtual Presence?|
Patrick J. Beisell, Mark P. Rotatori, E. Kendrick (Ken) Smith; Jones Day;
July 21, 2016, previously published on May 2016On May 3, 2016, the Supreme Court of Ohio heard oral argument between Crutchfield Corporation—a major electronics retailer based in Virginia—and Ohio Tax Commissioner Joseph Testa regarding whether Ohio can tax an out-of-state company based on sales of goods to Ohio consumers over the...
|IRS Accused of Improper Targeting Based on Organizations' Political Views|
Christopher Brian Best; Weltman, Weinberg & Reis Co., L.P.A.;
July 20, 2016, previously published on June 1, 2016The United States Court of Appeals for the Sixth Circuit rendered a strong decision recently, noting that no citizen should be targeted by an executive agency based on his or her political views.1 In 2010, the Treasury Department’s Inspector General for Tax Administration (“Inspector...
|New Ohio Municipal Corporation Tax Guidelines Impact Taxpayers|
Jack W. Hinneberg; Weltman, Weinberg & Reis Co., L.P.A.;
July 20, 2016, previously published on June 1, 2016New municipal income tax guidelines mandated by the State of Ohio went into effect on January 1, 2016 and effect how municipal corporations collect taxes from taxpayers. The changes are a result of the passage of Amended Substitute House Bill 5. All tax returns and payments for tax years prior to...
|Deferred No Longer: Treasury and IRS Issue Long-Awaited 409A Guidance|
Brenna M. Clark, Adam B. Cohen, Brittany Edwards-Franklin, Michael A. Hepburn, Cristopher D. Jones; Sutherland Asbill & Brennan LLP;
July 14, 2016, previously published on July 11, 2016On June 21, the Treasury Department and the Internal Revenue Service (IRS) issued proposed Internal Revenue Code (Code) section 409A regulations, modifying existing proposed and final section 409A regulations regarding deferred compensation arrangements. The proposed regulations consist of 19...
|Money for Nothing: Massachusetts Appeals Court Finds Intercompany Financing Transactions Did Not Constitute Genuine Indebtedness|
Zachary T. Atkins, Charles C. Kearns; Sutherland Asbill & Brennan LLP;
July 8, 2016, previously published on July 7, 2016The Massachusetts Appeals Court upheld an Appellate Tax Board decision disallowing interest expense on certain intercompany financing transactions because the underlying agreements did not establish an “unqualified obligation to repay.” The taxpayers, subsidiaries of a British utility,...
|Washington ALJ Rules Out-of-State Insurance Provider's Marketing Subject to Business & Occupation Tax as Other Services|
Jonathan A. Feldman, Alla Raykin; Sutherland Asbill & Brennan LLP;
July 8, 2016, previously published on July 7, 2016An administrative law judge (ALJ) held that a taxpayer’s activities in Washington were not selling, soliciting or negotiating insurance in the state, but rather marketing other in-state insurance companies’ products and receiving commissions from those marketing materials. Accordingly,...
|Compact, But No Contract: Minnesota Supreme Court Holds Compact Did Not Create Binding Contractual Obligation|
Amy F. Nogid, Hanish S. Patel; Sutherland Asbill & Brennan LLP;
July 8, 2016, previously published on July 6, 2016The Minnesota Supreme Court held that Minnesota’s adoption of the Multistate Tax Compact (Compact) did not create a binding contractual obligation and, as a result, the state’s subsequent repeal of the Compact’s alternative apportionment election provision was not prohibited as...