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|Ohio: Deadline Approaching for Small Businesses to Claim a 50 Percent Tax Deduction for the 2013 Tax Year|
David M. Kall, Susan Millradt McGlone; McDonald Hopkins LLC;
September 29, 2014, previously published on September 25, 2014The Ohio Department of Taxation has issued a release reminding small business owners that the deadline to claim a 50 percent income tax deduction is Oct. 15, 2014 for small business owners who have not yet filed their 2013 income tax return. This deduction was covered in our Feb. 20, 2014...
|The IRS and Treasury Issue New Anti-Inversion Guidance|
James R. Barry, Jason S. Bazar, Lee Morlock; Mayer Brown LLP;
September 26, 2014, previously published on September 25, 2014Following weeks of anticipation and speculation about administrative guidance on corporate inversions, the Internal Revenue Service (“IRS”) and the Treasury Department (“Treasury”) released Notice 2014-52 (“Notice”) on September 22, 2014, describing new...
|Brazil’s Internal Revenue Service Amends Provisions Covering Tax Rules for Legal Entities in the Tax Transition Regime|
Roberta P. Caneca, Ivan Tauil, Thais Bandeira de Mello Rodrigues; Mayer Brown LLP;
September 26, 2014, previously published on September 25, 2014The Federal Revenue Office published Normative Instruction No. 1,492/2014 on September 18, 2014, amending the provisions of Instruction No 1,397/2013 regarding the Transition Tax Regime (RTT).
|New Yorkers, Order Away - Restaurant Website Operator Not Subject to Sales Tax on Fees|
Timothy A. Gustafson, Jessica L. Kerner; Sutherland Asbill & Brennan LLP;
September 25, 2014, previously published on September 19, 2014 The New York Department of Taxation and Finance advised a website operator, through which restaurants offer meals for sale, that it was not subject to sales tax on the fees it charged to the restaurants for services provided. The website allows approximately 5,000 restaurants in more than 27 cities...
|M&A Update: Treasury Announces New Anti-Inversion Rules|
Cadwalader Wickersham Taft LLP;
September 25, 2014, previously published on September 23, 2014On September 22, 2014, the Treasury Department announced its intent to issue new regulations that will reduce the tax benefits available after an inversion and may make it more difficult for some U.S. companies to invert (the “Notice”). The Notice does not require congressional action...
|Senator Wyden Renews Push for Tax Extenders|
Sutherland Asbill Brennan LLP;
September 25, 2014, previously published on September 18, 2014The Congressional tax agenda for the end of 2014 is now clear: tax extenders and inversions. Even as inversions dominate the news, Senate Finance Committee Chairman Ron Wyden (D-Ore.) is continuing his push to pass legislation which extends expired tax provisions. On September 15, Senator Wyden...
|Limited Partners of Investment Managers may be Subject to Self-Employment Taxes|
Donald-Bruce Abrams, Charles R. Bogle, Anthony J. Carbone, Thomas Gray; Bingham McCutchen LLP;
September 25, 2014, previously published on September 15, 2014On September 5, 2014, the Internal Revenue Service (“IRS”) issued Chief Counsel Advice 201436049 (the “CCA”), concluding that members of an investment manager were subject to self-employment (“SE”) taxes with respect to their earnings from the investment manager....
|Lew: Inversion Guidance Coming “Very, Very Soon,” Rather than Just in the “Very Near Future”|
Sutherland Asbill Brennan LLP;
September 25, 2014, previously published on September 19, 2014Anti-inversion guidance from Treasury is now a near-certainty, but when they arrive and how they will operate remains a mystery. Treasury Secretary Jacob Lew used strong language to warn corporations against inverting in a September 17th interview with Bloomberg Television. “Any company...
|The New Deal: Hedge Fund Management Fees Are Subject to Social Security Taxes|
Mark H. Leeds; Mayer Brown LLP;
September 25, 2014, previously published on September 23, 2014It’s probably fair to speculate that there were significant numbers of tax aficionados (including the author of this article) among the audience for Ken Burns’ recent public television extravaganza on the Roosevelt dynasty. Unfortunately for this segment of the audience, the...
|IRS Finalizes and Clarifies Obamacare Reporting Rules|
Barry L. Klein; Blank Rome LLP;
September 25, 2014, previously published on September 2014Action Items: The IRS has finalized and clarified the ObamaCare health care coverage reporting requirements for “applicable large employers.” The reporting requirements are effective for 2015. Major system changes will likely be necessary in order to track all of the information that is...