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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

Base Erosion and Profit Shifting: The Australian Perspective

In July 2013, the G20 Finance Ministers, including Australia, fully endorsed the base erosion and profit shifting (BEPS) Action Plan. As a result of the Action Plan, the Australian government encouraged a new commitment to...more

The Lame Duck Has Arrived: What To Expect

In the great tradition of American democracy dating back to the election of the First Congress in 1778, voters cast their ballots last week, giving the Republican Party control of the upcoming 114th Congress. In a...more

IRS Ruling Creates Opportunities for Tax Savings by Companies With Substantial Real Estate Assets

On July 29, Windstream announced that it plans to spin off certain telecommunications network assets into an independent, publicly traded real estate investment trust (REIT). Windstream made the announcement after it obtained...more

Are REITs a Viable Strategy for Communications Companies?

Windstream Holdings, Inc. recently announced plans to spin off its copper, fiber and other fixed real estate assets into an independent publicly traded real estate investment trust (REIT). Windstream received a private letter...more

Is Your Purchaser Accredited? Clarifications from the SEC

Under Rule 506(c), companies can now engage in a general solicitation in conducting private placements but if they do so, they must verify that each purchaser is accredited. The SEC has provided some safe harbors for...more

International Tax News - June 2014

NEW FOR SUPPLIERS OF DIGITAL CONTENT AND INTANGIBLES: DLA PIPER’S GLOBAL VAT GUIDE - Starting January 1, 2015, EU VAT rules for suppliers of digital content, telecommunications and broadcasting services are changing....more

SEC Decision Regarding TIC Advertisements Offers Broader Lessons About Providing Fair and Balanced Disclosures

Earlier this year, the SEC found that CapWest Securities, Inc., a defunct broker-dealer, had failed to comply with advertising rules in promoting investments that use Section 1031 of the Internal Revenue Code (“1031...more

New Chapter For Foreign Telecom Investment In Shanghai Free Trade Zone

The telecom industry has traditionally been highly regulated and restricted in terms of foreign investment in China. China tightly controls what types of telecom business including basic telecom services (BTS) and value-added...more

Investment Management Update

Following two recent cases involving investment advisers and social media, the SEC recently issued guidance regarding whether the publication of comments about investment advisers on social media sites would violate those...more

MoFo New York Tax Insights - Volume 5, Issue 2 - February 2014

In This Issue: Governor Cuomo Releases Ambitious 2014-15 Executive Budget; Third Department Holds Transfer of Condemned Property Did Not Occur Until After Gains Tax Was Repealed; Trial Court Upholds Constitutionality...more

The Financial Report - Volume 2, No. 22 • December 12, 2013 (Global)

OSC to hold derivatives reporting seminar. The Ontario Securities Commission announced that it will hold a seminar on January 15, 2014, on the reporting requirements under the new Derivatives Trade Repositories and...more

International Tax News - December 2013

CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT - The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement. The IGA is the first step in bring the Cayman fund industry...more

State + Local Tax Insights -- Fall 2013

In This Issue: “Occasional Sales” and Single Sales Factor Apportionment in California; Upcoming Speaking Engagements; State Taxation of Financial Institutions; Applying the True Object Test to Determine the Taxability...more

Does A Radio Station Have Goodwill?

A recent Claims Court case addressed whether a radio station's assets include goodwill....more

United Kingdom: TV and Animation Cultural Test Finalised

The UK Government has published The Cultural Test (Television Programmes) Regulations 2013 (the “Regulations“) which will come into force on 13 August 2013....more

Corporate & Tax E-Note - June 27, 2013

In This Issue: - Secrecy Provision of JOBS Act Boosts IPO Pipeline - SEC Chair Says Companies Will Soon Have to Admit Wrongdoing - SBA Revises Standards Determining Small Business Sizes - Group Announces...more

Internet Fundraising for Tax-Exempt Organizations

The IRS recently released an Information Letter, written in response to a congressman’s inquiry about an unidentified charity’s unidentified practices, confirming that Section 501(c)(3) organizations may use the internet to...more

IRS Capitalized Legal Fees Incurred by Pharmaceutical Company

In a recently released Field Attorney Advice, the Internal Revenue Service (IRS) Office of Chief Counsel concluded that a pharmaceutical company must capitalize legal fees incurred to obtain Food and Drug Administration...more

Attorney General Prevails In Lawsuit Against Income Tax Preparation Company

The Attorney General brought a lawsuit against an income tax preparation business alleging violations of state and federal lending, consumer protection, unfair competition, and false advertising laws. The court of appeal...more

VODAFONE case and constitutionality of Finance Bill 2012

Validity of a clause in a Finance Bill containing a validation clause that seeks to negate the effect of an Apex court judgment that would otherwise operate in favor of VODAFONE by declaring that the concerned judgment shall...more

Bad Debts are Deductible for Pennsylvania Gross Receipts Tax Purposes - Provided Proper Documentation is Available

The Pennsylvania Department of Revenue recently issued Corporation Tax Bulletin 2011-02. The Bulletin provides some general guidance on the accounting method that must be used for computing the gross receipt taxes that...more

MoFo State & Local Tax Insights

In this issue: Honey, I Shrunk the Dormancy Periods!; No Solicitation: Sales Tax Nexus, the Amazon Law, and the Perils of Affiliate Advertising; and California Adopts Regulation Prescribing Sales and Use Tax Audit...more

Wikileaks Expose Interests IRS

Rudolf Elmer, a former employee of Julius Baer Bank in the Cayman Islands said he handed over to Julius Assange, the founder of Wikileaks documents containing the names and details of 2,000 people and companies who may have...more

Italy is Enforcing Tax on On-line Gaming winnings

Will the Italian enforcement efforts to force reporting of on-line gaming winnings be implemented in the U.S.? How will the sites adapt to the reporting requirements? The following article is of interest on these...more

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