Gregory J. Hartker

Gregory J. Hartker

K&L Gates LLP

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The Digital Economy: The Tax Man is Coming

Once again, we find ourselves faced with a proposal attempting to target and provide special tax rules for income generated in the digital economy. As was the case in the previous year’s budget proposal, the Administration’s...more

2/19/2015 - Digital Goods Digital Services Green Book IRS

Tax Challenges Raised by the Digital Economy

On September 16, 2014, the Organisation for Economic Cooperation and Development (“OECD”) released a report on Action 1 of the OECD/G20 Base Erosion and Profit Shifting Project (also known as the “BEPS” project) titled...more

11/20/2014 - Popular

OECD/G20 Base Erosion and Profit Shifting Project

On September 16, 2014, the Organisation for Economic Cooperation and Development (“OECD”) released seven reports addressing certain aspects of the base erosion and profit shifting (“BEPS”) project. The seven BEPS reports...more

11/20/2014 - BEPS EU European Commission G20 Information Reports OECD Tax Reform Tax Treaty

The Shadow Transfer Pricing Rules: Crediting Foreign Taxes

At the end of the 2013, the IRS issued, in the form of a Chief Counsel Advice [1] (CCA 201349015), its view on the applicability of transfer pricing concepts to transactions involving disregarded entities (“DEs”) in the...more

2/21/2014 - Foreign Tax IRS Tax Credits Transfer Pricing

The San Francisco Proposition E Gross Receipts Tax Ordinance: A Mixed Bag for Investment Fund Managers

On November 6, 2012, San Francisco residents approved Proposition E (the “Gross Receipts Tax Ordinance”) instituting a new gross receipts tax to replace the City’s 1.5% payroll tax. The new gross receipts tax is phased in...more

11/19/2012

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