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HTMLBundesverfassungsgericht Overturns Tax Privileges for Company Heirs
Michael Rainer, Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
May 12, 2015, previously published on May 11, 2015
On December 17, the German Federal Constitutional Court (Bundesverfassungsgericht) overturned tax privileges for company heirs which were said to be unconstitutional. The legislature has until mid-2016 to establish a new arrangement.

 

HTMLECJ: Inheritance Tax in Spain Discriminatory - Possible to Reclaim Inheritance Tax
Michael Rainer, Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
May 11, 2015, previously published on May 08, 2015
The European Court of Justice (ECJ) has found that Spanish inheritance and gift law unlawfully discriminates against foreigners who are living in Spain on a non-permanent basis.

 

HTMLCity of Philadelphia Requests Proposals to Implement Online Auction for Sale and Assignment of Delinquent Real Estate Tax Liens
Louise S. Melchor, Brett L. Messinger; Duane Morris LLP;
Legal Alert/Article
May 11, 2015, previously published on May 6, 2015
The City of Philadelphia recently announced a request for proposals to implement an online auction for the sale and assignment of some of the city's delinquent real estate tax liens. The auction will allow third parties to bid on the tax liens, with the successful bidder assigned the lien from the...

 

Adobe PDFFrench Tax Authorities Release a List of 17 Abusive Tax Schemes: The French Tax Administration Intends To Incentivize Taxpayers that Have Already Entered into Abusive Schemes To Regularize Their Situation
Gauthier Blanluet, Marie-Aimée Delaisi, Nicolas de Boynes; Sullivan & Cromwell LLP;
Legal Alert/Article
May 8, 2015, previously published on April 8, 2015
In July 2014, the French tax authorities released a first list of 11 abusive tax schemes. This list was generally viewed as non-contentious as it described obvious cases of abuses of law, which were not relevant for most corporate taxpayers.

 

HTMLAlas, the MTC Executive Committee Approves Its Transfer Pricing Program Design
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
May 8, 2015, previously published on May 7, 2015
After nearly a year of planning, the Multistate Tax Commission Executive Committee today approved the Arm’s-Length Adjustment Services Advisory Group (the Group) Final Program Design. The following six states have agreed to participate in the Program: Alabama, Iowa, Kentucky, New Jersey,...

 

HTMLDeeds of variation - will they survive?
Paul Hewitt; Withers Bergman LLP;
Legal Alert/Article
May 7, 2015, previously published on April 23, 2015
In the 2015 budget, the Chancellor announced 'I can also tell the House that we will conduct a review on the avoidance of inheritance tax through the use of deeds of variation. It will report by the autumn.'

 

HTMLUtah: Officials Tout the Bright Economic Outlook for 2015
David H. Godenswager, David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
Legal Alert/Article
May 7, 2015, previously published on April 23, 2015
Several prominent publications have been creating buzz for Utah’s business friendly environment over the last several months. These include Forbes’ March 19, 2015, article, How Salt Lake City And Utah Became The New Gold Standard, The New Yorker’s February 3, 2015, article, How...

 

HTMLMajor Changes To Capital Gains Tax
Sophie Carter; Withers Bergman LLP;
Legal Alert/Article
May 7, 2015, previously published on March 09, 2015
Under the current Capital Gains Tax (CGT) regime, a UK property owned by a non-resident and standing at a gain will not be taxed to CGT on sale. Given the buoyancy of the London property market in particular, this exemption has considerable value for overseas investors, especially as many other...

 

HTMLProtecting the Hospital Tax Exemption Part IV: Billing and Collection Requirements
Julie C. LaVille, Gary J. McRay; Foster, Swift, Collins & Smith, P.C.;
Legal Alert/Article
May 6, 2015, previously published on April 23, 2015
On December 31, 2014, the Internal Revenue Service (“IRS”) published final regulations providing guidance on how a hospital keeps its tax exemption by complying with Section 501(r) of the Internal Revenue Code. Section 501(r), which was added by the Patient Protection and Affordable...

 

HTMLFinal Regulations on Section 162(m) Deduction Limit Exceptions
Shane J. Stroud, Linda Z. Swartz; Cadwalader, Wickersham & Taft LLP;
Legal Alert/Article
May 6, 2015, previously published on Apr 28, 2015
New final regulations[1] (the “Final Regulations”) have been issued clarifying and altering the “qualified performance-based compensation” exception and the transitional “reliance period” exception for newly public companies to the $1 million limit on deductible...

 


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