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|United States Supreme Court Rejects Presumption of Prudence for Stock-Drop Cases|
Lori A. Basilico, Jonathan R. Shank; Edwards Wildman Palmer LLP;
July 1, 2014, previously published on June 2014In a highly anticipated decision, the United States Supreme Court held that fiduciaries of employee stock ownership plans (“ESOPs”) are not entitled to any special presumption of prudence when investing in employer stock. In Fifth Third Bancorp v. Dudenhoffer, the Supreme Court rejected...
|Buyer of Business Beware|
Theodore R. Goldstock; Lerch, Early & Brewer, Chartered;
July 1, 2014, previously published on June 13, 2014Many business people may be surprised at the story that follows, but it illustrates the need for buyers to be extremely careful when acquiring the assets of another business in Maryland. Business A was anxious to sell, and Business B was anxious to buy the assets of Business A. The transaction was...
|Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 30, 2014|
Matthew D. Lee, Jeffrey M. Rosenfeld; Blank Rome LLP;
July 1, 2014, previously published on June 2014The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other authority over, a foreign bank account (which includes bank,...
|New Legislation Expands Jurisdiction of Louisiana Board of Tax Appeals|
Jesse R. Adams, Andre B. Burvant, Matthew A. Mantle, Justin B. Stone; Jones Walker LLP;
July 1, 2014, previously published on June 2014On June 12, 2014, Governor Jindal signed into law HB 863 , which expands the jurisdiction of the Louisiana Board of Tax Appeals (the "BTA") and changes a number of state and loca l tax procedures; most importantly, those regarding appeals of assessments and refund claim denials. The...
|IRS Issues Favorable Private Letter Ruling to Data Center REIT|
Daniel R. McKeithen, R. Robinson Plowden, David A. Roby, William E. Sheumaker; Sutherland Asbill & Brennan LLP;
June 30, 2014, previously published on June 25, 2014On June 6, 2014, the Internal Revenue Service (IRS) released Private Letter Ruling 201423011 (the PLR), confirming that income from certain data center services can constitute “rents from real property” for purposes of the real estate investment trust (REIT) rules. Although the PLR is...
|Regulation No. 9/2014|
Marina Cyrino; Tauil & Chequer Advogados in association with Mayer Brown LLP;
June 30, 2014, previously published on June 23, 2014Regulation No. 9/2014 amended Regulation No. 7/2013 to reopen until 07/31/2014 the deadline for installments and payment of tax liabilities owed to the Treasury, authorized by Articles 1 to 13 of Law 11.941/2009 (Refis).
|California Senate and Assembly Vote to Extend Property Tax Exclusion for Solar|
Jason N. Barglow, Justus J. Britt; Foley & Lardner LLP;
June 30, 2014, previously published on June 26, 2014In furtherance of California’s commitment to renewable solar energy, the California Senate and Assembly recently passed Senate Bill 871 (SB 871) which, if signed, would extend the sunset date on the existing property tax exclusion for newly constructed solar energy systems from January 1,...
|Normative Expository Act No. 5 of June 16, 2014|
Roberta P. Caneca, Marina Cyrino; Mayer Brown LLP;
June 30, 2014, previously published on June 24, 2014On June 16, 2014, Brazilian Tax Authorities enacted Normative Expository (“ADE”) Act No. 5, which revoked the ADE No. 1/2000. The ADE No. 1/2000 provided for the application of withholding tax in Brazil to payments of service fees to overseas, regardless of the existence of a Tax Treaty...
|US Banking Regulators Issue Additional Guidance Regarding Tax Allocation Agreements in Holding Company Structures|
Scott A. Anenberg, Hayden D. Brown, J. Paul Forrester; Mayer Brown LLP;
June 30, 2014, previously published on June 20, 2014US banking regulators (the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency) have issued final joint supplemental guidance (Guidance) regarding tax allocation agreements involving holding companies and...
|Supreme Court Issues A Taxpayer Favorable Opinion in United States v. Clarke|
Geoffrey M. Collins, John T. Hildy, Brian W. Kittle; Mayer Brown LLP;
June 30, 2014, previously published on June 20, 2014The Supreme Court held on June 19, 2014, that taxpayers are entitled to examine IRS agents in a summons-enforcement proceeding where taxpayers “point to specific facts or circumstances plausibly raising an inference of bad faith.” The Court held that circumstantial evidence could meet...