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|Legislation Broadening Infrastructure Financing Districts Signed by Gov. Brown|
Sigrid K. Asmundson, T. Brent Hawkins, Seth Merewitz, Jake Vollebregt; Best Best & Krieger LLP;
October 8, 2014, previously published on October 6, 2014Four bills affecting infrastructure financing districts, a funding mechanism for infrastructure and development projects that benefit the broader community, were recently signed by Gov. Jerry Brown. IFDs, created in 1990, have garnered renewed interest after the dissolution of redevelopment in...
|U.S. Demonstrates Importance of FATCA Compliance through Recent Indictment|
Cristián Francos, Arthur D. Middlemiss, Hillary Rosenberg, Manuel S. Varela; Lewis Baach PLLC;
October 7, 2014, previously published on September 22, 2014A recent federal indictment demonstrates the strength of U.S. law enforcement efforts to combat offshore fraud and tax evasion and is the first case to charge crimes involving false filings and the use of nominee shareholders to circumvent FATCA reporting obligations.
|Tax Evasion: Number of Amended Tax Returns Has Doubled|
Michael Rainer, Michael Rainer; GRP Rainer LLP;
October 7, 2014, previously published on October 6, 2014The number of amended tax returns in cases of tax evasion continues to rise. According to media reports, it doubled in the first half of the year 2014 compared with the same period of the previous year.
|Commonwealth Court Rules that Pennsylvania Municipalities May Not Impose Business Privilege Tax on Rental Real Estate Business|
David M. Kuchinos; Blank Rome LLP;
October 7, 2014, previously published on October 2014Action Item: In a decision with wide-ranging implications and potential refund opportunities, Pennsylvania’s Commonwealth Court ruled on September 19th that Pennsylvania municipalities (other than Philadelphia) may not impose their business privilege tax (“BPT”) on a rental real...
|The Affordable Care Act—Countdown to Compliance for Employers, Week 13: IRS Notice 2014-49 Offers Useful Guidance on Changes in Measurement Periods or Changes in Testing Methods|
Alden J. Bianchi; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
October 6, 2014, previously published on September 29, 2014For purposes of complying with the Affordable Care Act’s employer shared responsibility rules (which are codified in Internal Revenue Code § 4980H), employers must identify their “full-time employees.” Final regulations issued under Code § 4980H provide two principle...
|The Affordable Care Act: Focus on Adjunct Faculty|
Patricia A. Moran; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
October 6, 2014, previously published on October 1, 2014The concepts of “hours of service” and “full time” loom large in the Affordable Care Act’s “employer shared responsibility” mandate (also known as the “employer mandate” or “pay or play mandate” and which we discussed in various...
|Cost-Efficient Alternatives for Document Production Gaining Traction|
Raj Madan, Christopher P. Murphy, Brendan T. O'Dell; Skadden, Arps, Slate, Meagher & Flom LLP;
October 3, 2014, previously published on October 2, 2014Tax controversies often involve voluminous document production and extensive privilege logs from multiple parties. The privilege issues can be complex and involve advice from multiple advisers potentially covering several different types of privilege protections, including attorney-client, work...
|Developmental Costs: Texas Comptroller Rules Essential Preparatory Costs Cannot Be Accounted for in Apportionment Factor|
Ted W. Friedman, Prentiss Willson; Sutherland Asbill & Brennan LLP;
October 3, 2014, previously published on September 29, 2014The Texas Comptroller determined that for Texas franchise tax purposes the apportionment factor of an out-of-state taxpayer engaged in the provision of technical training could not be adjusted to account for certain costs incurred in preparing and marketing the training sessions. The training...
|New Regulations Aimed at Discouraging Tax Inversions|
McDonald Hopkins LLC;
October 3, 2014, previously published on September 26, 2014On Monday, the Obama administration unveiled new rules intended to discourage corporations from moving their headquarters abroad to avoid paying U.S. taxes.
|S.D.N.Y. Judge Permits Novel Theory And Allows SEC To Use Unpaid Taxes As Measure Of Disgorgement In Securities Fraud Case|
Bruce M. Bettigole, Maia Cogen, Thomas A. Cullinan, Shanyn L. Gillespie, H. Karl Zeswitz; Sutherland Asbill & Brennan LLP;
October 3, 2014, previously published on September 29, 2014In a case against Dallas billionaires Sam Wyly and the estate of his late brother, Charles, Judge Shira Scheindlin of the U.S. District Court for the Southern District of New York agreed with the U.S. Securities and Exchange Commission (SEC) that the defendants were liable for unpaid taxes as...