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|The IRS and Treasury Issue New Anti-Inversion Guidance|
James R. Barry, Jason S. Bazar, Lee Morlock; Mayer Brown LLP;
September 26, 2014, previously published on September 25, 2014Following weeks of anticipation and speculation about administrative guidance on corporate inversions, the Internal Revenue Service (“IRS”) and the Treasury Department (“Treasury”) released Notice 2014-52 (“Notice”) on September 22, 2014, describing new...
|Brazil’s Internal Revenue Service Amends Provisions Covering Tax Rules for Legal Entities in the Tax Transition Regime|
Roberta P. Caneca, Ivan Tauil, Thais Bandeira de Mello Rodrigues; Mayer Brown LLP;
September 26, 2014, previously published on September 25, 2014The Federal Revenue Office published Normative Instruction No. 1,492/2014 on September 18, 2014, amending the provisions of Instruction No 1,397/2013 regarding the Transition Tax Regime (RTT).
|The New Deal: Hedge Fund Management Fees Are Subject to Social Security Taxes|
Mark H. Leeds; Mayer Brown LLP;
September 25, 2014, previously published on September 23, 2014It’s probably fair to speculate that there were significant numbers of tax aficionados (including the author of this article) among the audience for Ken Burns’ recent public television extravaganza on the Roosevelt dynasty. Unfortunately for this segment of the audience, the...
|Treasury Department and IRS Issue Long-Awaited Inversion Guidance|
Lester W. Droller, Andrew M. Eisenberg, Andrew M. Levine, Robert A. Profusek, Raymond J. Wiacek; Jones Day;
September 25, 2014, previously published on September 2014On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets forth rules that are generally effective for acquisitions completed on or after September 22, 2014, and will be included in regulations that will be...
|Washington State Issues Sharp Reminder Regarding Reliance on Advice from Department of Revenue: Don't Forget to Get It in Writing!|
Pilar Mata, Suzanne M. Palms; Sutherland Asbill & Brennan LLP;
September 25, 2014, previously published on September 22, 2014 The Washington Department of Revenue determined that taxpayers have a right to rely on written but not oral instructions from the Department of Revenue. The taxpayer operated an Internet marketing business and sold its services to customers both inside and outside the state. In June 2011, 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;
September 25, 2014, previously published on September 4, 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...
|Senator Wyden Renews Push for Tax Extenders|
Sutherland Asbill Brennan LLP;
September 25, 2014, previously published on September 18, 2014The Congressional tax agenda for the end of 2014 is now clear: tax extenders and inversions. Even as inversions dominate the news, Senate Finance Committee Chairman Ron Wyden (D-Ore.) is continuing his push to pass legislation which extends expired tax provisions. On September 15, Senator Wyden...
|IRS Finalizes and Clarifies Obamacare Reporting Rules|
Barry L. Klein; Blank Rome LLP;
September 25, 2014, previously published on September 2014Action Items: The IRS has finalized and clarified the ObamaCare health care coverage reporting requirements for “applicable large employers.” The reporting requirements are effective for 2015. Major system changes will likely be necessary in order to track all of the information that is...
|New Yorkers, Order Away - Restaurant Website Operator Not Subject to Sales Tax on Fees|
Timothy A. Gustafson, Jessica L. Kerner; Sutherland Asbill & Brennan LLP;
September 25, 2014, previously published on September 19, 2014 The New York Department of Taxation and Finance advised a website operator, through which restaurants offer meals for sale, that it was not subject to sales tax on the fees it charged to the restaurants for services provided. The website allows approximately 5,000 restaurants in more than 27 cities...
|Lew: Inversion Guidance Coming “Very, Very Soon,” Rather than Just in the “Very Near Future”|
Sutherland Asbill Brennan LLP;
September 25, 2014, previously published on September 19, 2014Anti-inversion guidance from Treasury is now a near-certainty, but when they arrive and how they will operate remains a mystery. Treasury Secretary Jacob Lew used strong language to warn corporations against inverting in a September 17th interview with Bloomberg Television. “Any company...