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HTMLMaryland Seeks Cash, Not Credit, Before Supreme Court
Sutherland Asbill Brennan LLP;
Legal Alert/Article
November 28, 2014, previously published on November 13, 2014
On 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...

 

HTMLThe Three Most Common Tax Traps for US Persons Moving to the UK
Lara Crompton, Stephen Nerland; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 13, 2014
There 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...

 

HTMLOn-Premises Fringe Benefits, Part I: Is There Such a Thing as a Free Lunch?
Vicki M. Nielsen; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
Legal Alert/Article
November 28, 2014, previously published on November 13, 2014
It 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...

 

HTMLBackflow To Add to Growing PTAB Workload
Scott A. McKeown; Oblon, Spivak, McClelland, Maier & Neustadt, L.L.P.;
Legal Alert/Article
November 28, 2014, previously published on October 30, 2014
As 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%...

 

HTMLTreasury Dropping Hints on Earnings Stripping
Sutherland Asbill Brennan LLP;
Legal Alert/Article
November 28, 2014, previously published on November 10, 2014
Treasury 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...

 

HTMLColorado 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;
Legal Alert/Article
November 28, 2014, previously published on November 25, 2014
The 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...

 

HTMLWho's Afraid of FATCA?
Richard Cassell, Jaime McLemore; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 13, 2014
We 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...

 

HTMLCorporate Inversions: How US Shareholders May Be Adversely Affected
Maya Ladno; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 13, 2014
Due 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...

 

HTMLCollateral Debt
Penelope Williams; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 13, 2014
With 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...

 

HTMLSwitzerland Moves Toward Automatic Information Exchange
Paul L. Behling; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 20, 2014
Swiss 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.

 


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