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|Regulation No. 9/2014|
Marina Cyrino; Tauil & Chequer Advogados in association with Mayer Brown LLP;
June 30, 2014, previously published on June 23, 2014Regulation No. 9/2014 amended Regulation No. 7/2013 to reopen until 07/31/2014 the deadline for installments and payment of tax liabilities owed to the Treasury, authorized by Articles 1 to 13 of Law 11.941/2009 (Refis).
|Federal Banking Regulators Issue Confirmatory Guidance on Tax Refund Ownership|
Peter J. Rivas; Jones Walker LLP;
June 27, 2014, previously published on June 19, 2014On June 13, 2014, federal banking regulators issued final supplemental guidance on income tax allocation agreements involving holding companies and insured depository institutions. Regulators sought to eliminate confusion among holding companies, depository institutions and their affiliates...
|U.S. Treasury Releases Final Rules on Tax Practitioner Written Advice, Competency and Risk Management|
Padric Kelly O'Brien; Taft Stettinius & Hollister LLP;
June 27, 2014, previously published on June 24, 2014On June 12, 2014, the United States Treasury Department published long-awaited regulatory changes to Circular No. 230 regarding several key aspects of practice before the Internal Revenue Service (“IRS”). Effective immediately, many of the June 14 rules fundamentally alter the way...
|Supreme Court Clarifies Standard to Challenge IRS Summons|
Roland Barral, David W. Foster, Armando Gomez, Julia M. Kazaks; Skadden, Arps, Slate, Meagher & Flom LLP;
June 27, 2014, previously published on June 20, 2014On June 19, 2014, the U.S. Supreme Court in United States v. Clarke held that a taxpayer has a right to conduct an examination of IRS officials regarding their reasons for issuing an administrative summons when the taxpayer points to specific facts or circumstances plausibly raising an inference of...
|New Canada-U.S. Initiative to Track Time Spent in Either Country Will Spotlight Cross-Border Tax Obligations|
Natasha Miklaucic; Borden Ladner Gervais LLP;
June 27, 2014, previously published on June 19, 2014Beginning June 30, 2014, Canada and the U.S. will implement a new joint initiative to share information with each other about when individuals cross the Canada-U.S. border to enter and leave their respective countries. This initiative will allow both countries to accurately track the whereabouts of...
|The Future of Gift Aid|
Graham Elliot; Withers Bergman LLP/Withers LLP;
June 26, 2014, previously published on June 24, 2014Conversations are underway between the Charity Tax Group ('CTG') and HMRC in respect of a potentially major reform to the operation of the gift aid rules, particularly in connection with donations which give rise to benefits to the donor.
|Illinois: Special Joint Committee Recommends Changes to the State Tax Code to Attract More Businesses|
McDonald Hopkins LLC;
June 25, 2014, previously published on June 19, 2014The Tax Policy Subcommittees of the Illinois General Assembly’s Joint Revenue & Finance and State Government Administration Committees (the “Joint Committees”) recommended a number of changes to the Illinois tax code in a joint report (the “Report”) issued on May...
|Colorado: New Law Passed Presuming Sales Tax Nexus for Out-Of-State Retailers|
McDonald Hopkins LLC;
June 25, 2014, previously published on June 19, 2014On June 6, 2014, Colorado Governor John Hickenlooper signed H.B. 1269, also known as the Marketplace Fairness and Small Business Protection Act, into law. H.B. 1269, which becomes effective on July 1, 2014, expands the array of activities that create state tax nexus for out-of-state retailers, and...
|US Announces Changes to the Offshore Voluntary Disclosure Programs|
Withers Bergman LLP/Withers LLP;
June 25, 2014, previously published on June 20, 2014On 18th June the US Internal Revenue Service (IRS) announced major changes to its offshore voluntary compliance programs, resulting in new guidance for both taxpayers overseas and those residing in the US.
|Tax Court of Canada Litigation Update: Henco Industries Limited v. HMQ|
Eric Mayzel, Geoffrey B. Shaw, Melissa Wright; Cassels Brock & Blackwell LLP;
June 24, 2014, previously published on June 18, 2014The recent Tax Court of Canada decision in Henco Industries Limited v. Her Majesty the Queen, provides litigation and tax practitioners with guidance on evidentiary and substantive tax issues.