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HTMLHeisman Would Be Proud: Taxpayer Stiff-Arms Indiana DOR with Transfer Pricing Studies
Stephen A. Burroughs, Jonathan A. Feldman; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
January 5, 2016, previously published on January 04, 2016
The Indiana Tax Court granted summary judgment to Columbia Sportswear USA Corp., (“Columbia”), determining that: (1) Indiana’s alternative apportionment statute did not permit the Department to equitably adjust Columbia’s tax base; and (2) Indiana’s standard sourcing...

 

HTMLCongress Delivers Holiday Gift in Form of Permanent Extenders Package
Amanda Wilson, Joseph W. Zitzka; Lowndes, Drosdick, Doster, Kantor & Reed Professional Association;
Legal Alert/Article
January 5, 2016, previously published on December 18, 2015
This week, Congress delivered a holiday gift to the country in the form of a permanent extenders package. The Protecting Americans from Tax Hikes Act of 2015 ("PATH Act") passed in the House of Representatives yesterday and is expected to be passed in the Senate today. President Obama has...

 

HTMLPath Act Brings Important Tax Changes for REITS
Amanda Wilson; Lowndes, Drosdick, Doster, Kantor & Reed Professional Association;
Legal Alert/Article
January 5, 2016, previously published on December 21, 2015
Last Friday, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 ("PATH Act"), a permanent extenders package. Several provisions of the PATH Act are of particular importance to REITs. The PATH Act largely implements the REIT proposals contained in the Tax...

 

HTMLTaxing Changes: Evolution of the CRA's Powers
Emily A. Gray, Michael J. Hewitt; Singleton Urquhart LLP;
Legal Alert/Article
January 5, 2016, previously published on December 15, 2015
Recent court decisions have advanced the ability of the Canada Revenue Agency to investigate and pursue tax cases. The impacts on tax professionals can be seen both in the penalties that can be imposed on accountants and lawyers directly and in the CRA’s ability to access client documents.

 

Adobe PDFAffordable Care Act’s Cadillac Tax on High Cost Health Plans Delayed Two Years
Brian P. Fox, Katherine A. Hesse; Murphy, Hesse, Toomey & Lehane, LLP;
Legal Alert/Article
January 5, 2016, previously published on December 2015
On December 18, 2015, Congress passed and President Obama signed a federal budget bill for 2016, including $1.1 trillion in spending and $622 billion in taxes. Also attached to the budget bill were several changes to the Affordable Care Act (“ACA”), most notably a two-year delay in...

 

HTMLCalifornia Supreme Court Holds Multistate Tax Compact is Not Binding
Michele Borens, Jonathan A. Feldman, Todd A. Lard, Carley A. Roberts, Leah Robinson; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
January 4, 2016, previously published on December 31, 2015
On December 31, 2015, the California Supreme Court closed the book on California’s Multistate Tax Compact election saga, unanimously holding that the Compact is not a binding contract among its members and the State was not bound by its provisions before the State’s repeal of the...

 

HTMLWhat's Good for Today's Goose Is Not So Good for Yesterday's Gander: California Board of Equalization Rejects Taxpayer's Retroactive Economic Nexus Argument
Timothy A. Gustafson, Evan M. Hamme; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
January 4, 2016, previously published on December 30, 2015
The California State Board of Equalization (Board) unanimously rejected Craigslist, Inc.’s (Craigslist) argument that California’s adoption of a factor-presence nexus regime in 2009 reflected pre-existing federal constitutional nexus standards pursuant to which Craigslist would be...

 

HTMLAustralian High Court Finds Liquidators Are Not Required to Set Aside Money for Pre-Assessed Tax Liabilities
Philip Hoser, Tim L'Estrange; Jones Day;
Legal Alert/Article
December 30, 2015, previously published on December 2015
The liquidators of Australian Building Systems Pty Ltd ("ABS") caused ABS to enter into a contract for the sale of real property, which gave rise to a capital gain tax event. The liquidators sought a private ruling from the Commissioner of Tax on the question of whether they had an...

 

HTMLBrazilian Congress Amends Proposed Capital Gains Rate Increases in Medida Provisória N. 692
S. Wade Angus, Marcello Hallake, Sanjiv K. Kapur, Luiz Felipe Noronha, Luis Riesgo; Jones Day;
Legal Alert/Article
December 30, 2015, previously published on December 2015
On September 22, 2015, the Brazilian federal government proposed a new rule—Medida Provisória n. 692/2015 ("MP 692")—increasing the income tax rates applicable to capital gains realized by certain taxpayers from a transfer or sale of assets or rights in Brazil. Medidas...

 

HTMLWay, Way Back: Retroactivity in the Proposed 2801 Regulations
Erin L. Fraser; Butler Snow LLP;
Legal Alert/Article
December 29, 2015, previously published on December 11, 2015
Individuals who relinquished U.S. citizenship since 2008 may find themselves with U.S. tax exposure for gifts they made before they expatriated under proposed regulations announced by the IRS. Under the current expatriation tax regime which came into effect on June 17, 2008, certain individuals who...

 


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