General Business Commercial Real Estate Tax

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Overview of UK Real Estate Structures and Transactions

This Overview provides a general summary of the different corporate structures that may be used to hold, and transact in, UK real estate (such as special purpose vehicles, property unit trusts, partnerships and REITS), the...more

Breaking The Code

I saw the movie Imitation Game last weekend, which is the story of Alan Turing and his role in breaking the Enigma Code which shortened World War II and saved millions of lives. (Spoiler Alert: He did it, we won.) Turing,...more

Rescission: Another Remedy to Address Unintended Tax Consequences

While the equitable remedy of rectification is often sought as a means to address unintended tax consequences, rescission is also an available remedy in the appropriate cases. The British Columbia Supreme Court’s decision in...more

Commercial Buildings in D.C. Face Potential Big Property Tax Increases Due in 2015

Landlords and tenants of commercial buildings in the District of Columbia should brace for potentially significant increases in their property taxes payable in 2015 and future years. The District of Columbia Office of Tax...more

The Economic Development Toolbox: “The Clean-Up Hitters” – Enterprise Zone and Community Reinvestment Area Property Tax Exemptions

Capital investment projects often involve tight margins, and every single dollar counts to ensure that the project is a success. For that reason, property tax exemptions are key components of any economic development...more

New UK Withholding Tax Exemption Set to Boost the UK Private Placement Market

On 4 December, George Osborne in his Autumn Statement, announced a new UK withholding tax exemption for interest payments on UK private placements. The announcement was followed by draft legislative clauses with the Finance...more

Business Privilege Taxes Paid On Leases Refund/Appeal Filing Needed By March/April 2015

On September 19, 2014, the Pennsylvania Commonwealth Court in Fish, Hrabrick and Briskin v. Township of Lower Merion, No. 1940 C.D. 2013, held that lease receipts are not taxable under local business privilege tax ordinances....more

Autumn Statement 2014

Yesterday, the Chancellor of the Exchequer delivered the UK 2014 Autumn Statement. Below we summarise some of the main announcements: Taxation of multi-nationals - Diverted profits tax (aka the "Google tax")...more

PA Tax Law News - December 2014

In This Issue: - Recent PA Sales Tax Guidance Concerning Natural Gas and Other Mining Activities - Focus on Pennsylvania Corporate Taxes - Application and Sale of Restricted Tax Credits -...more

High Court Affirms Theater, Church’s Entitlement to State’s “Mandatory” Property Tax Exemption

The Court of Appeals, New York’s highest court, recently published decisions in the Maetreum of Cybele v. McCoy and Merry-Go-Round Playhouse, Inc. v. Auburn cases. In these decisions, the Court affirmed that the exemptions...more

The Secret Is Out: The Documentary Transfer Tax Will Now Be Part of Public Record

The Documentary Transfer Tax Act allows each county and city to impose a tax on each deed, instrument, or writing by which any real estate is sold within the county at the time the document is recorded. Assembly Bill No....more

Pennsylvania Department of Revenue Clarifies Changes to New Realty Transfer Tax Law

The Pennsylvania Department of Revenue recently released an Information Notice explaining the implications of Act 52 of 2013, which enacted some significant changes to the Pennsylvania realty transfer tax, effective January...more

IRS Rules That Some Basis in Solar System Must Be Allocated to Structural Functions

On October 31, the IRS released Private Letter Ruling 201444025, which was addressed to a manufacturer of solar systems that are mounted on real estate. The nature of the real estate, along with many other interesting facts,...more

Going Multijurisdictional - Laying the groundwork for shared business parks

It is a basic, universally accepted fact that in order for an area to win new recruitment projects—and in some cases retain expansions of an existing company facility that will be on a site other than its current...more

Pa. Department of Revenue Delivers Good News and Bad News Regarding New Realty Transfer Tax Provisions

The Pennsylvania Department of Revenue (DOR) recently issued Information Notice - Realty Transfer Tax 2014-01 (the Information Notice) delivering some good news and bad news about how the new law that became effective January...more

California Seeks to Clarify Standards of Review for Hotel Property Tax Assessment Appeals

Hotels are one of the most misunderstood properties when valued by local assessors for property tax purposes. A hotel’s enterprise activity is comprised of tangible property, in the form of real estate and personal property,...more

Recent Decision on Imposing a Business Privilege Tax

The Commonwealth Court has rendered a significant decision regarding ability of municipalities to impose a business privilege tax on the gross receipts generated by real estate leases. The Pennsylvania Commonwealth Court, in...more

Following FASB: Leases, Revenue Recognition Proposals On the Horizon

There are two proposals making their way through FASB that will have far-reaching implications for most financial statements—including those of private companies. Even though neither of these proposals has been finalized,...more

Southeast State & Local Tax: Important Developments - September/October 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA - INDIVIDUAL INCOME TAX...more

Sale-leasebacks accommodate buyer and seller in today’s healthcare real estate market: 7 reasons why they work, 5 pitfalls to note

For many years, low interest rates allowed companies with strong credit ratings to obtain access to cheap capital through traditional financing methods – meaning there was little enthusiasm for sale-leaseback...more

New Scottish property transaction tax: Highest rate band for commercial property announced as 4.5%

John Swinney, the Scottish government's Finance Secretary, has announced the proposed rates and bands for the new Scottish property transaction tax known as the Land and Buildings Transaction Tax (LBTT). On 1 April...more

B.C. Supreme Court Rescinds Land Transfers

In Re 0741508 BC Ltd and 0768723 BC Ltd (2014 BCSC 1791), the British Columbia Supreme Court (“BCSC”) considered whether rescission should be granted in respect of two real estate transactions in which the applicant...more

Leases Not Subject to Business Privilege Taxes - Commonwealth Court Case Presents Refund Opportunities

The Pennsylvania Commonwealth Court, in a 5-2 decision, held that the Local Tax Enabling Act ("LTEA") bars taxing jurisdictions from imposing business privilege taxes, on leases or lease transactions. Fish, Hrabick and...more

Commonwealth Court Rules That Pennsylvania Municipalities May Not Impose Business Privilege Tax on Rental Real Estate Business

Action Item: In a decision with wide-ranging implications and potential refund opportunities, Pennsylvania’s Commonwealth Court ruled on September 19th that Pennsylvania municipalities (other than Philadelphia) may not impose...more

International Tax News - September 2014

BASE EROSION PROFIT SHIFTING PROJECT RECOMMENDATIONS TO COMBAT TAX AVOIDANCE BY MULTINATIONALS - At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering...more

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