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|IRS Does Not Reduce Winning Thresholds for Casino Information Reporting & Will Not Track Electronic Players Cards for Tax Purposes|
Marvin A. Kirsner; Greenberg Traurig, LLP;
January 11, 2017, previously published on December 30, 2016In a major win for the gaming industry today, the Treasury Department published regulations that do not reduce winning thresholds for a casino’s tax information reporting obligations, and will not track electronic player cards for tax information purposes.
|The Latest Word on Subsequent Legislative History and the GAAR|
Jared A. Mackey; Bennett Jones LLP;
January 11, 2017, previously published on November 01, 2016Two recent decisions of the Tax Court involving the general anti-avoidance rule (GAAR), Univar Holdco Canada ULC v The Queen, 2016 TCC 159 [Univar] and Oxford Properties Group Inc v The Queen, 2016 TCC 204 [Oxford Properties], have added to the array of inconsistent and controversial case law on...
|Citigroup False Claims Act Lawsuit Remanded to New York State Court for Lack of Federal Question Jurisdiction|
Zachary T. Atkins, Marc A. Simonetti; Sutherland Asbill & Brennan LLP;
January 11, 2017, previously published on January 6, 2017A federal district court denied a taxpayer’s motion to dismiss a lawsuit brought under the New York False Claims Act (FCA) for lack of subject matter jurisdiction and remanded the action to state court. The relator, an Indiana University professor, alleges that Citigroup violated the FCA by...
|MA ATB Determines a Securities Corporation Subsidiary Must File Required Application to Receive Favorable Tax Status as a Securities Corporation|
Eric J. Coffill, Alla Raykin; Sutherland Asbill & Brennan LLP;
January 11, 2017, previously published on January 10, 2017The Massachusetts Appellate Tax Board (ATB) upheld the Commissioner’s assessment, resulting from a denial of a subsidiary’s securities corporation classification for corporate excise tax purposes. Companies classified as securities corporations receive favorable excise tax treatment...
|Pardon My French, But You're A Taxpayer: Out-of-State Baker's Croissants Lead to B&O Nexus in Washington|
Zachary T. Atkins, Timothy A. Gustafson; Sutherland Asbill & Brennan LLP;
January 11, 2017, previously published on January 9, 2016The Washington State Department of Revenue ruled that an out-of-state baker whose only in-state “presence” was its use of in-state independent commissioned sales representatives to solicit orders had substantial nexus with Washington and therefore was subject to the state’s...
|West Virginia Court Rules that Credit for Taxes Paid to Other States Must Include Local Taxes|
Open Weaver Banks, Michael J. Kerman; Sutherland Asbill & Brennan LLP;
January 11, 2017, previously published on January 5, 2017The West Virginia Supreme Court held that a credit for taxes paid to other states on purchases of motor fuel is constitutional only if interpreted to include taxes paid to subdivisions of other states. The court determined that a credit that applies only to taxes paid to other states, and not...
|Syndicated Conservation Easement Transactions Indentified as New "Listed Transactions"|
Arianna Caldwell, Christopher S. Rizek, Charles M. Ruchelman; Caplin & Drysdale, Chartered;
January 11, 2017, previously published on January 3, 2017On December 23, 2016, the Internal Revenue Service (“IRS”) issued Notice 2017-10 identifying certain transactions involving conservation easements as “listed transactions.” For several years the IRS has been actively examining conservation easements and litigating such cases...
|A More Taxing World for UK Property Loans|
Sophie Dworetzsky, Paul Fairbairn, Katie Graves, Christopher Groves, Justine Markovitz; Withers Bergman LLP;
January 11, 2017, previously published on December 6, 2016In the July 2015 Budget George Osborne announced that all beneficial owners of UK residential property would be brought within the charge to inheritance tax, regardless of how that property was held.
|Italy Introduces a Territorial System of Taxation|
Giulia Cipollini, Giada Mazzola, Giorgio Vaselli; Withers Bergman LLP;
January 11, 2017, previously published on December 12, 2016Italy has recently introduced a territorial system of taxation to attract high net worth individuals, including successful individuals in the sports, arts, and fashion and design sectors, who could be interested in moving to Italy to take part in these thriving sectors. The new measure is contained...
|California Appeal Court Upholds $2.8 Million Refund for Comcast on Unitary Business Issue|
Madison J. Barnett, Chelsea E. Marmor; Sutherland Asbill & Brennan LLP;
January 9, 2017, previously published on January 3, 2017The California Court of Appeal upheld Comcast’s $2.8 million franchise tax refund, determining that: (1) Comcast and its subsidiary QVC were not unitary, such that QVC was properly excluded from Comcast’s combined group, and (2) a termination fee Comcast received from a failed merger...