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|A Decent Proposal to Reform the Tax Treatment of Derivatives?|
John Kaufmann; Greenberg Traurig, LLP;
July 7, 2016, previously published on June 10, 2016At the American Bar Association midyear meeting in January of this year, two panelists who spoke about the straddle rules contained in Internal Revenue Code (Code) section 1092 were asked what they expected would happen to the straddle rules over the subsequent 10 years. One panelist said that she...
|New Rules Concerning the Correction of Errors in Assessment of Real Property Taxes Will Go Into Effect in NYC|
Glenn Newman; Greenberg Traurig, LLP;
July 7, 2016, previously published on June 14, 2016On June 16, 2016, new Rules issued by the New York City Department of Finance (the Department) regarding the correction of errors concerning the assessment of real property taxes go into effect. Title 19 of the Rules of the City of New York was amended to add a new Chapter 53 authorizing the...
|New York Issues Two Advisory Opinions Regarding Surplus Lines Insurance|
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
July 1, 2016, previously published on July 1, 2016The New York State Department of Taxation and Finance (Department) issued two advisory opinions determining that unauthorized non-life insurance corporations (here, surplus lines insurance companies) are subject to insurance franchise tax (under N.Y. Tax Law § 1502) instead of premium tax...
|Alabama Regulation Requires Software Update: Tax Tribunal Holds Modified Software Is Nontaxable Custom Software|
Eric J. Coffill, Hanish S. Patel; Sutherland Asbill & Brennan LLP;
June 30, 2016, previously published on June 29, 2016The Alabama Tax Tribunal held that a taxpayer was entitled to a refund of sales taxes paid on purchases of software that was modified for its exclusive use because it constituted nontaxable custom software. Relying on its regulation, the Alabama Department of Revenue (DOR) denied the refund,...
|South By Southwest: Texas Supreme Court Rejects Processing Exemptions for Oil Company|
Charles C. Capouet, Todd A. Lard; Sutherland Asbill & Brennan LLP;
June 28, 2016, previously published on June 28, 2016The Supreme Court of Texas held that an oil and gas exploration and production company’s purchases of casing, tubing, other well equipment, and associated services were not exempt from sales tax under various processing exemptions. Texas provides multiple exemptions from sales tax for certain...
|New York Calling: Phone Card Kiosk Sales Subject to Sales Tax, but Not Telecommunications Excise Tax|
Timothy A. Gustafson, Douglas J. Upton; Sutherland Asbill & Brennan LLP;
June 27, 2016, previously published on June 24, 2016The New York State Department of Taxation and Finance issued an Advisory Opinion concluding that a retail operator of kiosks selling various prepaid telecommunication plans and additional telecommunication rights for existing plans was subject to New York sales and use tax collection and remittance...
|Tax Court Rejects IRS Transfer Pricing Approach in Medtronic|
Joseph A. (Joe) Goldman, Lori A. Hellkamp, Karl L. Kellar, Edward T. (Ed) Kennedy; Jones Day;
June 26, 2016, previously published on June 2016Medtronic Inc. & Consolidated Subsidiaries v. Commissioner (T.C. Memo. 2016-112) is the latest defeat for the U.S. Internal Revenue Service ("IRS") in a string of transfer pricing losses. The IRS sought to increase royalties payable from a Puerto Rico affiliate to Medtronic, Inc....
|New Regulations Intended to Encourage Consolidation|
Stephen J. Fyfe, Daniel Lang; Borden Ladner Gervais LLP;
June 23, 2016, previously published on June 13, 2016The Ministry of Finance ("MOF") published two regulations on April 25, 2016, implementing the changes described in the April 2015 Ontario Budget. The new regulations are intended to encourage the consolidation of the LDC sector by reducing, and in some cases eliminating significant tax...
|Mississippi Tax Bulletin - April 2016: Mississippi Legislature Passes Significant Tax Relief|
Alveno N. Castilla, J. Paul Varner; Butler Snow LLP;
June 21, 2016, previously published on May 6, 2016On April 18, 2016, the Mississippi Legislature passed Senate Bill 2858 and enacted the “Taxpayer Pay Raise Act of 2016.” Lieutenant Governor Tate Reeves describes the Act as the largest tax relief package in Mississippi history. The changes made by the Act are estimated to save...
|Don’t be Phased by Annuity Treatment: Taxation of Distributions During Phased Retirement|
Brenna M. Clark, Adam B. Cohen, Brittany Edwards-Franklin, Thomas A. Gick, W. Mark Smith; Sutherland Asbill & Brennan LLP;
June 21, 2016, previously published on June 21, 2016On June 10, the Internal Revenue Service (IRS) issued Notice 2016-39 in response to inquiries regarding the appropriate tax treatment under section 72 of the Internal Revenue Code (the Code) for payments received by an employee from a qualified defined benefit plan during phased retirement. For...