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Washington State Imposes New Reporting Requirements for Out-Of-State Sellers Not Collecting Sales Tax

by Stoel Rives LLP on

As part of Washington State’s efforts to collect more sales tax on out-of-state companies’ sales to Washington customers, the Legislature recently enacted H.B. 2163. The bill, signed by the Governor on July 7, imposes notice...more

Corporate Inversions

by Kelley Drye & Warren LLP on

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

Good News for Taxpayers: IRS Targets for Reform Burdensome Regulations on Partnerships, Corporations, REITs, Estates, and More

Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more

ILPA Issues Guidance on “Subscription Lines of Credit and Alignment of Interests”

by Goodwin on

Subscription lines of credit, or capital call facilities – which are just two of the many names given to borrowing arrangements put in place by private fund managers at the fund level – have been in the market for many years...more

Anti-Corruption Digest - July 2017

by Dorsey & Whitney LLP on

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more

July 2017 Federal Tax Alert – New Partnership Audit Regulations

The U.S. Treasury Department and the Internal Revenue Service (“IRS”) recently reissued 277 pages of proposed regulations and a preamble (REG-136118-15) regarding the new centralized partnership audit rules enacted as part of...more

California Supreme Court Confirms: Pony Up the Documentary Transfer Tax

by Nossaman LLP on

The California Supreme Court just dealt a blow to taxpayers who transfer interests in real estate-owning LLCs and other entities. In 926 North Ardmore Avenue, LLC v. County of Los Angeles (Cal. S. Ct. No. S222329, June 29,...more

Deferring Taxes but Keeping the Cash

by Slim Ventures LLC on

In recent years, many public and private companies have been able to defer capital gains tax on appreciated assets while keeping up to 95% of the proceeds (versus 65%-75% in paying taxes). ...more

Competition News - June 2017

by Dentons on

Admissibility before the CJEU of evidence communicated by national authorities during a tax investigation - In a case of unlawful agreement on the banana market, the Court of Justice of European Union (“CJEU”) had the...more

Tax Savings in the United States Virgin Islands – the Basics

by Garvey Schubert Barer on

When many people think of the United States Virgin Islands (“USVI”), they think of beautiful beaches on secluded islands. This is certainly correct, but many people do not know that the USVI is also home to some of the most...more

Saudi Arabia Update - June 2017

by Dentons on

Legal Developments - 10 minute SAGIA License - Companies carrying any foreign ownership in Saudi Arabia are required to have a foreign investment license issued by the Saudi Arabian General Investment Authority (SAGIA)...more

Tax Round Up - June 2017

by Proskauer Rose LLP on

International Tax Developments - BEPS Multilateral Convention signed - On 7 June, officials from more than 60 jurisdictions signed the BEPS Multilateral Convention which will transplant a number of measures in respect...more

What the New Kansas Income Tax Bill Will Mean for Individuals and Businesses

by Stinson Leonard Street on

The saga of Kansas income tax law changes concluded earlier this week when Kansas lawmakers overrode Gov. Sam Brownback's veto of a bill that dismantled the governor's signature tax cuts. With the state facing an estimated...more

“Tax-Free” Exchanges May Not Be Free of Tax

by Farrell Fritz, P.C. on

Business owners love to hear the words “tax-free” when considering the disposition of business assets. Unfortunately, many fail to grasp that a tax-free disposition is rarely free of tax in the sense of never being taxed;...more

The Dream of a Gross Receipts Tax Is Alive in Oregon

by Garvey Schubert Barer on

After Oregon Measure 97’s drubbing at the polls in November 2016, for many, it suggested the quashing of any notion of a gross receipts tax in the state. For Oregon Senator Mark Hass (D) and Representative Mark Johnson (R),...more

IRS Issues New Rules for Management Contracts involving Tax-Exempt Financed Facilities

by Miller Canfield on

The Internal Revenue Service (IRS) issued Revenue Procedure 2017-13 (Rev. Proc. 2017-13) on Jan. 17, 2017. The procedure provides more flexible, modern rules for structuring management contracts involving tax-exempt financed...more

Manufacturing Matters May 2017

by DLA Piper on

As mentioned in the last issue of Manufacturing Matters, “Smart Manufacturing”, including automation, is gaining momentum. A number of leading global manufacturers have already adopted it, and according to The Annual...more

Guidance For North-South Spinoffs

by Farrell Fritz, P.C. on

The IRS continues to issue guidance in the much debated area of corporate spinoffs. A recently published ruling examined the federal income tax treatment of the two steps that comprise a so-called “north-south” transaction.”...more

Tax administrations prepare for automatic exchange of CbC reports - are you ready? Three takeaways

by DLA Piper on

OECD announced that another important step has been taken to implement country-by-country (CbC) reporting requirements, as signatories to the Multilateral Competent Authority Agreement on the Exchange of CbC Reports (the CbC...more

IRS Issues Guidance on “North-South” Transactions

by Proskauer - Tax Talks on

On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the “Ruling”), which helpfully clarifies that the separate steps of a typical “north-south” spinoff transaction will be respected, and announced...more

Energy Transfer, Williams, and the Circular Ownership of Stock

It is unheard of for a deal to die at the closing table because lawyers cannot deliver a required opinion regarding a transaction that they structured and negotiated. Yet, this is exactly what happened last year when two...more

Waiver of contractual right

by Hogan Lovells on

In a binding private ruling published on 2 May 2017, SARS was requested to confirm the income tax, donations tax, capital gains tax and value-added tax consequences of the proposed waiver of a right to receive an annual...more

Nasdaq Report: Reigniting America’s Economic Engine

The Nasdaq recently published a report, titled “The Promise of Market Reform,” which sets out proposed structural changes that are intended to relieve some of the burdens associated with being a public company. The report...more

Practical Guidance on Merger Conditions from Williams v. Energy Transfer Equity

by Ropes & Gray LLP on

The Delaware Supreme Court’s recent 4-1 decision in The Williams Cos., Inc. v. Energy Transfer Equity, L.P., et al., which affirmed the Delaware Court of Chancery’s decision to allow a public company merger to be terminated...more

Corporate criminal liability risk increases for financial services

by Allen & Overy LLP on

The Criminal Finances Act 2017, which received Royal Assent last week, contains the largest expansion of UK corporate criminal liability since the Bribery Act 2010 and one of the most significant overhauls of money laundering...more

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