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|Best Practice Guidance for Responding To IRS 1098-T Proposed Penalty Notices, Collecting TINs|
Anne D. Cartwright; Husch Blackwell LLP;
October 23, 2014, previously published on October 9, 2014Colleges and universities are receiving another round of IRS Notice 972CG, proposing penalties for missing or incorrect Taxpayer Identification Numbers on Form 1098-T. Form 1098-Ts are information returns relating to higher education tuition and expenses; the TINs they request are most often...
|Avoid Taxes by Entering into a Cottage 1031 Safe Harbor|
Kate E. Flewelling; Smith Haughey Rice & Roegge, P.C.;
October 23, 2014, previously published on October 2, 20141031 exchanges are often considered by real estate investors when they look to cash out of an investment. Generally speaking, a 1031 exchange (also referred to as a “like-kind exchange”) is a swap of one business or investment asset for a similar asset. For example, you own asset X,...
|Ohio: The Tax Impact of House Bill 483|
McDonald Hopkins LLC;
October 23, 2014, previously published on October 16, 2014In 2011, in an effort to make Ohio’s government smaller, more efficient, and more effective, Gov. Kasich worked with the General Assembly to enact his fiscal year 2012-13 budget. This budget cut taxes, streamlined regulations, and reformed government.
|Oklahoma: District Court Invalidates Obamacare Subsidies|
McDonald Hopkins LLC;
October 23, 2014, previously published on October 16, 2014One of President Obama’s key initiatives, the Patient Protection and Affordable Care Act (ACA), has taken a beating since the president signed it into law on March 23, 2010.
|BEPS 2014 Deliverables - OECD Releases First Set of Recommendations|
TJ Kang, Brian O'Neill; McCarthy Tétrault LLP;
October 22, 2014, previously published on October 15, 2014Canada and other members of the Organisation for Economic Co-operation and Development (OECD) and the G-20 are engaged in a project to address “base erosion and profit shifting” (BEPS) strategies used by multinational enterprises (MNEs) and are working to achieve the goals set out in...
|Canadian Back-to-Back Loan Proposals|
Nigel P.J. Johnston, Gabrielle M.R. Richards; McCarthy Tétrault LLP;
October 22, 2014, previously published on October 15, 2014The 2014 federal budget included measures (Budget Measures) intended to eliminate the use of back-to-back loans to avoid the thin capitalization rules and/or withholding tax on interest paid to non-arm’s length non-residents so as to protect the Canadian tax base from erosion by limiting the...
|Skandia: Intra-Company Supplies Treated as Taxable Transactions for VAT Purposes by the Court of Justice of the European Union|
Adam Blakemore, Catherine Richardson; Cadwalader, Wickersham & Taft LLP;
October 22, 2014, previously published on September 24, 2014On 17 September 2104, the Court of Justice of the European Union (the “CJEU”) gave its preliminary ruling in the case of Skandia America Corporation USA, Sweden Branch v Skatterverket (C-7/13) (“Skandia”). The decision of the CJEU has been awaited with interest throughout...
|Voluntary Disclosure Leading To Immunity: Planned Tightening From January 1, 2015|
Michael Rainer, Michael Rainer; GRP Rainer LLP;
October 22, 2014, previously published on October 21, 2014The German government has approved a bill to tighten the rules for voluntary disclosure in the event of tax evasion. The law is expected to enter into force on January 1, 2015.
|Fourth Protocol to Canada-UK Treaty Eliminates Withholding Tax on Arm’s Length Interest, but Preserves Tax Exemption for Gains on Disposition of Shares and Interests Deriving Value from Canadian Real Property|
Elaine Buzzell, Nigel P.J. Johnston; McCarthy Tétrault LLP;
October 22, 2014, previously published on October 15, 2014On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of...
|IRS Warns Congress Over Tax Extenders|
McDonald Hopkins LLC;
October 19, 2014, previously published on October 10, 2014The Internal Revenue Service is warning Congress that decisions over renewing tax provisions that expired at the end of 2013 must be made by late November, or next year's tax-filing season could be seriously disrupted.