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HTMLIRS Concludes that a Fund Manager’s Activities Cause Offshore Private Fund to be Engaged in a Lending Business in the United States
Sutherland Asbill Brennan LLP;
Legal Alert/Article
February 13, 2015, previously published on January 23, 2015
In a recently released Internal Revenue Service (“IRS”) Chief Counsel Advice, CCA 201501013 (Sept. 5, 2014) (the “CCA”), the IRS concluded that the activities of a fund manager (“Fund Manager”) to originate loans on behalf of an offshore private fund (the...

 

HTMLOhio and Delaware Alert Taxpayers of End of Year Deadlines
David H. Godenswager, David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
Legal Alert/Article
February 13, 2015, previously published on December 31, 2014
The Cleveland Plain Dealer reports that under a program approved by voters in 2009, Ohio veterans who served in Iraq from March 19, 2003, to Dec. 31, 2011, have until Dec. 31, 2014, to apply for their Ohio Veterans Bonuses. According to the article, the bonus is not subject to state or federal...

 

HTMLTaxpayer Victories Are at a Premium: Alabama Court Holds that Business Privilege Tax "Premiums" Include Annuity Considerations
Andrew D. Appleby, Stephen A. Burroughs; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
February 13, 2015, previously published on January 28, 2015
The Alabama Court of Civil Appeals ruled in favor of an out-of-state life insurance company regarding the calculation of its Alabama net worth tax - the Business Privilege Tax (BPT). The BPT requires an insurance company to calculate its Alabama net worth based on the ratio its Alabama premium...

 

HTMLTax Extenders Bill Likely to Pass by Year End
Mark D. Klimek; McDonald Hopkins LLC;
Legal Alert/Article
February 13, 2015, previously published on December 12, 2014
The 2014 “Tax Extenders” bill was passed by the House of Representatives last week, paving the way for a last-minute reprieve for many popular tax breaks. It still requires approval by the Senate and the President, but all indications are that this will happen by the end of the year....

 

HTMLFlorida: Pre-filed Bills Propose Tax Cuts in Three Areas
David H. Godenswager, David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
Legal Alert/Article
February 13, 2015, previously published on December 11, 2014
At the end of Jan. 2014, Florida Gov. Rick Scott released his “It’s Your Money Tax Cut Budget” for fiscal year 2014-2015. As he repeated when he unveiled his budget, Gov. Scott’s tenure has focused on cutting taxes, reducing spending, and reducing debt. It is, therefore, not...

 

HTMLNew York Governor’s Budget Proposes Radical Tax Changes
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
February 13, 2015, previously published on February 3, 2015
New York Governor Andrew Cuomo introduced his 2015-2016 budget and accompanying legislation on January 19, 2015 (the 2015 Budget Bill). If enacted, New York’s tax law will be significantly altered for the second time in two years. The sales tax provisions of the legislation will tax most...

 

HTMLNew Mexico Allows New Combined Reporting Group to Use NOL Carryforwards from Separate Filers
Andrew D. Appleby, Derek Takehara; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
February 13, 2015, previously published on January 29, 2015
The New Mexico Department of Taxation and Revenue granted a combined reporting group’s corporate income tax protest by allowing the group to claim a deduction for net operating losses (NOLs) that two of its members generated and reported previously on a separate entity basis. The taxpayer was...

 

HTML2015 Commercial Property Tax Appeals
Thomas J. Denitzio, John J. Reilly; Greenbaum, Rowe, Smith & Davis LLP;
Legal Alert/Article
February 12, 2015, previously published on February 2015
Some of New Jersey’s commercial, industrial and multi-occupancy property owners have seen signs of an economic rebound, but many continue to face challenges to their bottom line precipitated by factors such as lower rental incomes and higher vacancy rates. Others may face property value...

 

HTMLNew Federal Law Allows Savings Accounts for Individuals with Disabilities
Michael A. Bush; Bowles Rice LLP;
Legal Alert/Article
February 9, 2015, previously published on January 13, 2015
Effective January 1, 2015, the Achieving A Better Life Experience Act (ABLE), a new federal law, provides another tool for special needs planning.

 

HTMLNY Sales Tax Hits Passive Investors in Limited Partnerships and Limited Liability Companies
Eric Homsi, Mark A. Limardo; Olshan Frome Wolosky LLP;
Legal Alert/Article
February 6, 2015, previously published on January 12, 2015
Next time you think about investing some “play” money in your friend’s trendy new restaurant, make sure you know what you’re getting into. If you’re not careful, you could find yourself on the hook for much more than you bargained for.

 


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