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|Repatriation Holiday in the Driver’s Seat?|
Sutherland Asbill Brennan LLP;
July 3, 2014, previously published on June 25, 2014Senator Harry Reid (D-Nev.) and Sen. Rand Paul (R.-Ky.) are in negotiations on a one-time repatriation “holiday,” which would allow U.S. corporations to repatriate foreign earnings at a special reduced rate. No proposal has formally been released, but reports on the negotiations say...
|The RF SAC Presidium Position: The Form of Notification on Controlled Transactions|
Dentons Canada LLP;
July 3, 2014, previously published on June 18, 2014On February 25, 2014, the RF SAC Presidium set aside the RF SAC decision deeming the form of notification on controlled transactions approved by the FTS Russia compliant with the RF TC and returned the case for reconsideration (RF SAC Presidium Ruling No. 18588/13 of February 25, 2014,...
|MTC Speaks with Potential Transfer Pricing Vendors|
Sutherland Asbill Brennan LLP;
July 3, 2014, previously published on June 26, 2014On June 25, the Arm’s Length Adjustment Services Advisory Group (the Group) of the Multistate Tax Commission (MTC) met via teleconference to continue the process of developing a multistate arm’s length pricing adjustment service. States participating in the meeting included Alabama,...
|Tennessee "Volunteers" Taxpayer for Alternative Apportionment|
Andrew D. Appleby, Stephen Burroughs; Sutherland Asbill & Brennan LLP;
July 3, 2014, previously published on June 27, 2014The Tennessee Court of Appeals held that the Commissioner had the authority to require Vodafone, a wireless communications provider, to use an alternative apportionment method for Tennessee franchise and excise tax purposes. Vodafone used Tennessee’s statutory cost-of-performance (COP) method...
|Signed, Sealed, Delivered, They're Ours: Illinois Sources Cloud Computing Receipts Using Market-Based Approach|
Sahang-Hee Hahn, Pilar Mata; Sutherland Asbill & Brennan LLP;
July 3, 2014, previously published on June 27, 2014The Illinois Department of Revenue determined that a taxpayer’s cloud computing receipts should be sourced for sales factor purposes using a market-based approach because the receipts were derived from services. The taxpayer was an information technology hosting services provider engaged in a...
|IRS Begins Section 409A Compliance Initiative|
Vicki M. Nielsen; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
July 2, 2014, previously published on June 26, 2014The Internal Revenue Service (IRS) is getting ready to ramp up enforcement of Section 409A of the Internal Revenue Code. The federal agency recently announced the launch of a new project to assess the level of taxpayer compliance with Section 409A-the provision that regulates nonqualified deferred...
|Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 30, 2014|
Matthew D. Lee, Jeffrey M. Rosenfeld; Blank Rome LLP;
July 1, 2014, previously published on June 2014The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other authority over, a foreign bank account (which includes bank,...
|United States Supreme Court Rejects Presumption of Prudence for Stock-Drop Cases|
Lori A. Basilico, Jonathan R. Shank; Edwards Wildman Palmer LLP;
July 1, 2014, previously published on June 2014In a highly anticipated decision, the United States Supreme Court held that fiduciaries of employee stock ownership plans (“ESOPs”) are not entitled to any special presumption of prudence when investing in employer stock. In Fifth Third Bancorp v. Dudenhoffer, the Supreme Court rejected...
|Buyer of Business Beware|
Theodore R. Goldstock; Lerch, Early & Brewer, Chartered;
July 1, 2014, previously published on June 13, 2014Many business people may be surprised at the story that follows, but it illustrates the need for buyers to be extremely careful when acquiring the assets of another business in Maryland. Business A was anxious to sell, and Business B was anxious to buy the assets of Business A. The transaction was...
|FICA Special Timing Rule for Nonqualified Deferred Compensation Applies Even When Employees Never Receive Deferred Amounts|
Marla J. Blackburn Aspinwall, Megan A. Stombock; Loeb & Loeb LLP;
July 1, 2014, previously published on June 2014The Federal Insurance Contributions Act (FICA) tax is comprised of a Social Security tax, currently at a 6.2 percent rate for each of the employer and employee on wages up to $117,000 (the Social Security "wage base") and a Medicare tax, currently at a 1.45 percent rate for each of the...