General Business Tax

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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 15 key elements to be addressed by 2015 for a co-ordinated international approach to combat tax...more

Now You See It, Now You Don’t: MTC Election Disappears in Michigan?

On September 11, 2014, Michigan Governor Rick Snyder signed S.B. 156, which purports to repeal the state’s adoption of the Multistate Tax Compact (the Compact) retroactive to January 1, 2008. Mich. Pub. Acts 2014, No. 282...more

Cook County Ordered to Start Processing Use Tax Refund Claims By September 24, 2014

On September 17, 2014, the Circuit Court of Cook County entered summary judgment in favor of the Chicagoland Chamber of Commerce, represented by Reed Smith LLP (“Reed Smith”), on the remaining count of their Complaint...more

Devon: TCC considers large corporation rules

In Devon Canada Corporation v. The Queen the issue is whether the taxpayer (“Devon”) may deduct $20,884,041 paid to cancel issued stock options. After the close of pleadings, the Crown brought a procedural motion relating to...more

International Tax Alert: OECD Releases BEPS Papers

Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS). These constitute the “building blocks” for an internationally agreed and co-ordinated response...more

Can We Talk? Providing Hedge Fund Managers with the Deferral of Carried Interest until Eternity

Overview - The recent passing of Joan Rivers not only requires us to pay tribute to one of the great comedic minds of the last forty-fifty years, but serves as a testimony to professional passion, perseverance and hard...more

Dutch Tax Plan 2015 and other changes in Dutch tax law

Today, the Dutch Ministry of Finance published its Tax Plan 2015 (hereinafter: Tax Plan). The Tax Plan primarily has an impact on citizens of the Netherlands, especially employees. The impact for the business community...more

OECD Releases 2014 BEPS Deliverables

On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package)....more

Grunderwerbsteuer: Das Ende von 94/6-Strukturen bei Personengesellschaften?

Bundesfinanzhof verschärft den Rahmen für steueroptimierte Akquisitionsstrukturen durch mittelbare Zurechnung nach wirtschaftlichen Maßstäben . Thema der aktuellen Entscheidung – In einer am 10. September 2014...more

Recent State Supreme Court Decision Prompts Repeal of Michigan Multistate Tax Compact (MTC)

Public Act 282 of 2014, signed into law by Governor Snyder on September 11, 2014, repeals the Multistate Tax Compact's three-factor apportionment election for multistate businesses, effective as of January 1, 2008. The Act is...more

Minnesota Issues Revenue Notice Regarding Apportionment of Compensation Paid to Nonresident Corporate Board Members

On August 25, 2014, the Minnesota Department of Revenue released Revenue Notice 14-02, which provides an alternative method of apportioning compensation earned by certain corporate directors who are not residents of Minnesota...more

PA Tax Law News - September 2014

In This Issue: - Sales Factor Sourcing of Services & Intangibles - Nonresident Limited Partners Liable for Personal Income Tax - PA Appeal Systems Changes Update - Personal Responsibility for...more

A (Somewhat) Brief History of Local Sales Taxes

Though usually a sure-fire cure for insomnia for anyone other than a policy wonk or local government finance officer, local sales taxes have been a hot topic of debate recently in three high-profile news stories. ...more

Guide To Doing Business in Australia: Taxation

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

Canadian government vs. Ottawa think tank - a battle of bias

Classic case of they said, they said - Last year, the Canada Revenue Agency began auditing an Ottawa-based think tank, accusing the company of being “biased and one-sided.” Now, more than 400 academics are demanding...more

Private Ruling Endorses Taxpayer-Friendly Reading of “Qualified Small Business” Under Section 1202

On September 5, 2014, the Internal Revenue Service (“IRS”) released Private Letter Ruling 201436001 (the “Ruling”), which found that a company providing products and services primarily within the pharmaceutical industry was a...more

German Real Estate Transfer Tax: The end of so-called 94/6 Partnership Structures?

German Federal Fiscal Court severely tightens framework for acquisition structures by using beneficial ownership as the standard for the attribution of indirect participations. Key Subject of the Decision - With a...more

The Mergers & Acquisitions Review: Eighth Edition: Chapter 11: British Virgin Islands

I OVERVIEW OF M&A ACTIVITY - British Virgin Islands (BVI) companies are employed in geographically diverse corporate structures, with the effect that gradually improving global economic conditions have started to...more

How to Land Projects in California

Until recently, California’s state-level economic development cupboard was looking a little bare — its 400 redevelopment agencies were dissolved in February 2012, property tax increment financing has been discontinued and...more

Why Does My Joint Venture Pay Corporate Taxes? When Tax Status Doesn’t Match State Form

Most of the time the state-law classification of an entity and its federal income tax classification match. A corporation will be taxed as a corporation and a partnership will not be taxed, instead merely filing an...more

RRSP Eligibility for Renewable Energy Co-Operatives: Could there be a solution at last?

One of the major obstacles facing renewable energy co-operatives is the concern that, although they are a co-operative for the purposes of the Cooperative Corporations Act (Ontario) (the “CCA”), they may not be co-operatives...more

Gariepy: When is a director’s resignation effective?

In Gariepy v. the Queen (2014 TCC 254), the Tax Court considered (i) whether two directors had effectively resigned from their positions, and (ii) if not, whether the directors were duly diligent in seeking to prevent the...more

Avoiding and Defending Florida License Tax Audits

Florida hotels and restaurants are facing license tax audits, assessments and penalties in increasing numbers. A "license" is statutorily defined as the granting of a privilege to use or occupy a building or real property....more

Editorial: Qualifying for Treaty Benefits Under the “Derivative Benefits” Article

Foreign persons are subject to U.S. federal income tax on a limited basis. Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on...more

Three Point Shot

Female Football Player Throws Flag at LFL over Bare Wages - The three-year championship run of the Los Angeles Temptation was snapped in 2013 when the upstart Chicago Bliss, led by the quarterback and two-time league...more

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