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|Maryland Seeks Cash, Not Credit, Before Supreme Court|
Sutherland Asbill Brennan LLP;
November 28, 2014, previously published on November 13, 2014On Wednesday, November 12, 2014 the United States Supreme Court heard oral arguments in Comptroller of Maryland v. Wynne. The case turns on whether Maryland’s personal income tax system violates the dormant Commerce Clause of the United States Constitution because of Maryland’s failure...
|The Three Most Common Tax Traps for US Persons Moving to the UK|
Lara Crompton, Stephen Nerland; Withers Bergman LLP;
November 28, 2014, previously published on November 13, 2014There are a number of important US and UK tax issues that a US citizen or green card holder should consider prior to becoming a tax resident in the UK; however, people often fail to take advice prior to moving. This article discusses the three most common tax traps that we see on a day-to-day basis...
|On-Premises Fringe Benefits, Part I: Is There Such a Thing as a Free Lunch?|
Vicki M. Nielsen; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
November 28, 2014, previously published on November 13, 2014It is no secret that many Silicon Valley employers serve free gourmet meals to their employees—the Wall Street Journal, Bon Appétit magazine, Time, Forbes, and other media sources have reported on this benefit. In addition, the number and variety of cafés and foods provided by...
|Backflow To Add to Growing PTAB Workload|
Scott A. McKeown; Oblon, Spivak, McClelland, Maier & Neustadt, L.L.P.;
November 28, 2014, previously published on October 30, 2014As discussed on Tuesday, sometimes the Court of Appeal for the Federal Circuit (CAFC) will find it necessary to remand an appeal to the Patent Trial & Appeal Board (PTAB). Likewise, sometimes the Solicitor will seek remand in appropriate circumstances. Historically remand occurs in about 10-15%...
|Treasury Dropping Hints on Earnings Stripping|
Sutherland Asbill Brennan LLP;
November 28, 2014, previously published on November 10, 2014Treasury Department officials are stating publicly the potential methods it is considering to reduce the benefit of inversion transactions through so-called “earnings stripping.” According to reports of an October 29 panel discussion, Treasury is considering cutting back on interest...
|Colorado Colocation Consternation: Department of Revenue Gives General Guidance on Application of Sales and Use Tax to Colocation and Hosting Facility|
Timothy A. Gustafson, Evan Hamme; Sutherland Asbill & Brennan LLP;
November 28, 2014, previously published on November 25, 2014The Colorado Department of Revenue issued guidance to a taxpayer operating a colocation and hosting facility, which provided customers a place to securely store computer servers, on whether certain charges imposed by the taxpayer were subject to sales and use tax. Specifically, the taxpayer...
|Who's Afraid of FATCA?|
Richard Cassell, Jaime McLemore; Withers Bergman LLP;
November 28, 2014, previously published on November 13, 2014We are now firmly in the FATCA era and moving on to the post FATCA era. With the first FATCA reports being submitted in March 2015, by now many FFIs have registered and obtained their GIINs, trustees are documenting their trusts, holding companies have entered into appropriate sponsorship...
|Corporate Inversions: How US Shareholders May Be Adversely Affected|
Maya Ladno; Withers Bergman LLP;
November 28, 2014, previously published on November 13, 2014Due to a rapid rise in the number of transactions and the resulting potential losses for the US Department of Treasury, corporate inversions are a current hot topic in Washington. The US corporations which enter into these transactions defend their actions, at least in part, by highlighting their...
Penelope Williams; Withers Bergman LLP;
November 28, 2014, previously published on November 13, 2014With effect from 4 August 2014, HMRC changed, without notice, their stated position with respect to the treatment of commercial loans secured by foreign income or gains. From this point on, money brought to or used in the UK under a loan facility secured by foreign income or gains is to be treated...
|Switzerland Moves Toward Automatic Information Exchange|
Paul L. Behling; Withers Bergman LLP;
November 28, 2014, previously published on November 20, 2014Swiss Bank secrecy and data protection have been eroded by The Department of Justice investigations and the Foreign Account Tax Compliance Act (FATCA). Switzerland has now taken a formal move toward greater transparency.