Science, Computers & Technology Tax

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CFPB to Assume a Larger Role in Virtual Currency Initiatives

On June 26, 2014, the U.S. Government Accountability Office (“GAO”) released a report, entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report, delivered earlier to...more

Congress Returns from July 4th Recess - What to Expect in the Coming Months

Although the 113th Congress continues to see a dearth of legislation seeing final approval, over the past six months, Congress has managed to finalize Fiscal Year 2014 appropriations; address the Sustainable Growth Rate...more

Division of Tax Appeals Rules Patent License Fees Not Subject to Sales Tax in New York

A New York State Division of Tax Appeals administrative law judge (ALJ) recently ruled in favor of a medical device and technology company on the question of whether patent license fees that the company charged to its...more

Intangible Services, Rights And Digital Content: Global VAT Guide

Welcome to DLA Piper’s Global VAT Guide: Cross Border Supplies of Intangible Services, Rights and Digital Content. As business grows more global, the challenge for in-house counsel and in-house VAT specialists is...more

Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 2014

The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more

Capital Thinking: Technology and Communications

Legislative Activity Online Competition and Consumer Choice Act of 2014 Introduced in the House and the Senate Last Tuesday, June 17, Senator Patrick Leahy (D-Vermont) and Representative Doris Matsui (D-California)...more

New York Ruling Raises Questions About The Taxation of Cloud Computing Services

When you were a child, lying faceup on a grassy knoll in the yard, staring at the clouds, what did you see? Animals? Faces? Tall ships on the high seas? Or perhaps you felt left out and never understood why people claimed to...more

FDA to Cease Active Regulation of MDDS and Other Health IT Devices

The draft guidance also enables some health IT manufacturers to avoid the device tax. The Food and Drug Administration (FDA) took an unusual step on June 20 by issuing new draft guidance that states its intent to not...more

Health Update - Jun 2014

Removing Regulatory Barriers to Accelerate EHR Adoption - Recognizing the potential long-term value of EHRs for improving care and reducing costs, many hospitals considered offering physicians financial support to...more

Interactive Gaming Incentives in the United States

There’s been a lot of press about places that are unfriendly to gamers or game developers. Authorities in various jurisdictions have attempted to address issues of violence, sex, and gambling, either resident in or allegedly...more

Legal Alert: Internet Tax Freedom Act Extension Clears Congressional Committee

On June 18, the Judiciary Committee of the U.S. House of Representatives voted in favor of H.R. 3086, the Permanent Internet Tax Freedom Act (PITFA) by a vote of 30-4. PITFA permanently extends the moratorium on state and...more

Corporate Inversions Showing No Signs of Slowing Down

In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or...more

The IRS will not flag, identify or otherwise note a SSN that may be subject to identity theft and subsequent tax fraud. Go figure....

Nearly every day there’s another news story about another company suffering a data breach, either as a result of a lost or stolen device or because the company was hacked. Talk to any number of knowledgeable attorneys skilled...more

Bitcoin Reportability and Taxation

June 30 is the deadline for taxpayers with a connection to foreign financial accounts to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). As this is the first year in which all FBARs must be...more

Bitcoins Do Not Require FBAR Filing

I have been posting a lot of FBAR-related posts lately. Here’s one more. There has been a question whether owners of “bitcoins” and other virtual currencies that have non-U.S. aspects, are subject to annual reporting...more

MoFo New York Tax Insights - Volume 5, Issue 6 - June 2014

In This Issue: - New York Court Grants Airbnb’s Motion to Quash Attorney General’s Subpoena - New York City UBT Ruling Allows Broker-Dealer Sourcing for Non-Registered Broker-Dealers - ALJ Dismisses Action as...more

Delhi High Court upholds Centrica ruling: employee secondment may trigger permanent establishment

Multinationals with operations in India should take note of the Delhi High Court’s recently decision in Centrica India Offshore Pvt Ltd., in which it upheld a ruling of the Authority for Advance Rulings that an employee...more

Tax Planning for the Privatization of the Space Industry

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more

Pennsylvania Tax Developments - A Reed Smith Quarterly Update: May 2014

This is a brief update on recent Pennsylvania tax developments. For more information on any of these developments, contact one of the authors or the Reed Smith State Tax attorney with whom you usually work....more

IRS Ruling Addresses Application of Medical Device Excise Tax in Contract Manufacturing Arrangement

In Private Letter Ruling 201420004 (released May 16, 2014), the Internal Revenue Service (IRS) has ruled on the question of which party in a contract manufacturing arrangement is the "manufacturer" for purposes of the medical...more

Regulation Of Bitcoin Around The World

Governments and tax authorities continue to develop their fiscal and tax positions relating Bitcoins. Many countries are releasing warnings about the risks associated with the use of Bitcoins, with some providing more...more

Estate Planning and Tax Issues for Bitcoin and Other Virtual Currencies

For estate planning and tax advisers, it’s important to know about all of a person’s valuable and significant assets, including digital assets, so that they can help the person properly plan ahead for incapacity, death, and...more

IRS Notice Has Profound Impact on Tax Treatment of Bitcoin

Recently, I had a client ask me about accepting payments in Bitcoin due to perceived reduction in transaction costs. Unfortunately, there is a recent IRS ruling that makes the future of Bitcoin as a medium of exchange...more

Investing in Bitcoin? Think Twice Says the SEC.

Bitcoin has been in the news a lot recently and most of the news has been bad, including news of the bankruptcy of Mt. Gox, formerly one of the world’s largest Bitcoin exchanges. Most recently, on May 7, 2014, the SEC issued...more

Inversion Transactions Likely to Continue and Expand into Other Markets and Industries

During recent months there has been a surge in cross-border M&A activity in which U.S. and non-U.S. companies combine in so-called inversion transactions. Examples of these transactions are Endo International’s acquisition of...more

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