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|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....
|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...
|Anti-Inversion Notice Issued: IRS and Treasury Issue Guidance Intended to Reduce the Tax Benefits of Inversion Transactions|
Sullivan Cromwell LLP;
September 25, 2014, previously published on September 24, 2014On September 22, 2014, the Internal Revenue Service (the “IRS”) and the Treasury Department (the “Treasury”) issued Notice 2014-52 (the “Notice”) announcing that the Treasury and the IRS intend to issue regulations that will address inversion transactions and...
|California Taxpayer Entitled to Attorney Fees after Successful Commerce Clause Challenge|
Zachary T. Atkins, Prentiss Willson; Sutherland Asbill & Brennan LLP;
September 25, 2014, previously published on September 22, 2014 A California Court of Appeal held that a taxpayer who brought a successful facial challenge against a state taxing scheme met all of the requirements for an award of attorney fees and that the trial court abused its discretion by failing to award the fees. The taxpayer, an individual, sought a...
|OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns|
J. Clark Armitage, Peter A. Barnes, Elan P. Keller, Neal M. Kochman, Patricia Gimbel Lewis; Caplin & Drysdale, Chartered;
September 23, 2014, previously published on September 23, 2014On September 16, 2014, the Organization for Economic Cooperation and Development (OECD) released its 2014 deliverables on the Base Erosion and Profit-Shifting (BEPS) project. The BEPS project, an ambitious and wide-ranging effort by the OECD’s Centre for Tax Policy and Administration (CPTA),...
|IRS Affirms Treatment of Short Sales for UBTI Purposes|
Jonathan R. Talansky; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
September 23, 2014, previously published on Sepember 12, 2014Since there are many hedge funds that utilize short selling as part of their investment strategy, it is important for hedge fund investors, including tax exempt organizations, to understand the U.S. tax treatment of these transactions. Fortunately for the exempt investors, the IRS has taken a...
|Planned Amendments to Income Taxes|
Karina Furga-Dabrowska, Cezary Przygodzki, Dariusz Stolarek; Dentons Canada LLP;
September 23, 2014, previously published on September 17, 2014On 16 September 2014, the Polish President signed the Act of 29 August 2014 amending the Corporate Income Tax Act, the Personal Income Tax Act and certain other laws (Amendment). The planned date on which the Amendment would come into force, subject to certain transitional provisions, is 1 January...
|Draft of General Anti-Tax Avoidance Clause|
Karina Furga-Dabrowska, Rafal Mikulski, Cezary Przygodzki; Dentons Canada LLP;
September 23, 2014, previously published on September 15, 2014On September 10, 2014 the Council of Ministers announced a draft amendment to the Tax Ordinance regarding the “general anti-tax avoidance clause.”
|Recent Developments Pertaining to Ohio Tax Foreclosures|
Benjamin Hoen; Weltman, Weinberg & Reis Co., L.P.A.;
September 23, 2014, previously published on September 9, 2014 There have been several recent developments in Ohio concerning Tax Foreclosures. First, on September 2, 2014, the Ohio Supreme Court issued a decision clarifying a lien holder's standing to redeem properties from tax foreclosure, by paying the taxes prior to the confirmation of the sale. Second,...
|Including License Payments in the Customs Value of Good|
Dzhangar Dzhalchinov; Dentons Canada LLP;
September 23, 2014, previously published on September 17, 2014Issues relating to customs value have been a common source of questions since work began on legislation. With the customs authorities paying particular attention to whether companies are performing their obligations to pay license fees to intellectual property rights holders, the subject is...