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|Circuit Court Split Casts Doubt on PPACA Subsidies for Individuals and Employer Penalties in 36 States|
Brenna M. Clark, Adam B. Cohen, Andrea M. Gehman, Michael A. Hepburn, Paul R. Lang; Sutherland Asbill & Brennan LLP;
July 30, 2014, previously published on July 24, 2014Two federal appeals courts issued conflicting rulings on July 22 on whether individual premium subsidies under the Patient Protection and Affordable Care Act (PPACA) are available in 36 states that have federally run insurance exchanges. Because employer penalties can be triggered when employees...
|MTC Uniformity Committee Prepares for UDITPA Regulations|
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Marc A. Simonetti; Sutherland Asbill & Brennan LLP;
July 29, 2014, previously published on July 29, 2014On July 28, the Multistate Tax Commission (MTC) Uniformity Committee tabled two projects to free up resources to work on apportionment regulations in anticipation of the full Commission vote later this week that could amend several key UDITPA sourcing rules.
|Authorized Economic Operator: Recent Changes|
Dentons Canada LLP;
July 29, 2014, previously published on July 9, 2014Recent amendments to the Federal Law on Customs Regulation in the RF (as amended by Federal Law No. 115-FZ on Amendments to the Federal Law on Customs Regulation in the Russian Federation of May 5, 2014 with respect to the institution of authorized economic operator) (the "Law") have made...
|Model Transaction Tax Overpayment Act Gains Traction at MTC|
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Ted W. Friedman, Todd A. Lard; Sutherland Asbill & Brennan LLP;
July 29, 2014, previously published on July 28, 2014On July 21, the Multistate Tax Commission’s (MTC) Uniformity Committee voted unanimously to send to the MTC’s Executive Committee a draft resolution recommending that the MTC endorse a model transaction tax act which, if enacted by the states, would limit frivolous lawsuits seeking to...
|Multistate Tax Commission Targets Summer 2015 Implementation of Transfer Pricing Effort|
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
July 29, 2014, previously published on July 29, 2014On July 28, the Arm’s Length Adjustment Services Advisory Group (Group) of the Multistate Tax Commission (MTC) met for the third time at the MTC Annual Conference in Albuquerque, New Mexico. The Group began this effort on June 2 and met again on June 25 in furtherance of a Summer 2015...
|Due Diligence Review Essential For Larger Transactions|
Michael Rainer, Michael Rainer; GRP Rainer LLP;
July 29, 2014, previously published on July 29, 2014In the case of larger transactions, including in particular the acquisition of companies, shares in companies or investment property such as real estate, a careful risk assessment is indispensable. This kind of due diligence review provides all the relevant information for the planned purchase.
|A Brief Overview of 2014 Iowa Tax Law Changes|
Kristy Rogers; Nyemaster Goode P.C.;
July 28, 2014, previously published on July 23, 2014During the 2014 legislative session, the Iowa General Assembly passed three minor tax reforms that Governor Branstad has signed into law.
|A Synopsis of the Cyprus Holding Company|
Aquilina Demetriadi; Anastasios Antoniou LLC;
July 28, 2014, previously published on Summer 2014Cyprus provides an established, stable and solid legislative framework under which Cyprus companies can be formed for intermediary or ultimate holding purposes within corporate groups, in project finance, cross-border transactions or even investment management contexts.
|Hospital lab services may not constitute unrelated trade or business: IRS Technical Advice Memorandum|
Wakaba Y. Tessier; Husch Blackwell LLP;
July 28, 2014, previously published on July 25, 2014On July 11, 2014, the Internal Revenue Service (“IRS”) released a Technical Advice Memorandum (“TAM”) dated March 7, 2008, which concluded that, contrary to the general rule set forth in Revenue Ruling 85-110 (“Rev. Ruling 85-110”), a tax-exempt hospital’s...
|The Prodigal Pension Plan Member|
Lorraine Allard; McCarthy Tétrault LLP;
July 28, 2014, previously published on July 16, 2014It’s one of those pension administration nightmares - someone of pensionable age shows up at your door claiming he was an employee 20 years ago and asks for his pension. There is some evidence of employment, but no record of a pension entitlement. As a fiduciary you cannot pay out benefits...