Double Taxation

News & Analysis as of

Reasonable Compensation Issues Remain On the IRS Radar Part II: S-Corporation Concerns

Our May 26, 2016 article, Reasonable Compensation Issues Remain on the IRS Radar ("Part I"), discussed how the IRS scrutinizes the reasonableness of compensation payments made to C-corporation shareholder-employees. As...more

New York Issues Two Advisory Opinions Regarding Surplus Lines Insurance

The New York State Department of Taxation and Finance (Department) issued two advisory opinions determining that unauthorized non-life insurance corporations (here, surplus lines insurance companies) are subject to insurance...more

Brexit: Tax Implications

The majority has spoken: on Friday 24 June, it was announced that the UK had voted to leave the European Union (the “EU”). The full implications of this decision are largely unknown, given that the UK is navigating...more

Brexit: What are the implications for tax law?

The precise impact of a Brexit on UK tax law is not possible to determine without knowing the terms of the exit negotiated by the UK with the EU and future government decisions. There are various ways the relationship between...more

Throwout: New Jersey Supreme Court Denies Certification

The New Jersey Supreme Court has denied certification in Lorillard Licensing Company LLC v. Director, Division of Taxation, making the Appellate Division's decision final. The Appellate Division affirmed the Tax Court in its...more

Washington ALJ Upholds B&O Assessment on German Company’s Royalty Income

On May 31, 2016, the Washington Department of Revenue (DOR) Appeals Division released a Determination (No. 15-0251, 35 WTD 230) denying a German pharmaceutical company’s business and occupation tax (B&O) protest. The...more

Taxpayer Required to Pay Tax Twice on the Same Income - Tax Court Unsympathetic

A taxpayer in the medical supply business received payments from Cigna before 2005. He reported those items in income and paid federal income tax on them. A dispute later arose and the taxpayer returned payments to...more

Florida Supreme Court: Origin Sourcing for Sales Tax is Constitutional

The Florida Supreme Court upheld the imposition of a sales tax obligation on an in-state florist for all of its worldwide sales regardless of delivery destination. This “origin sourcing” method of determining transactions...more

Florida Sales Taxes on Internet Sales Outside of Florida [Florida]

Question: A Florida corporation, with a physical location and principal address in Florida, sells flowers, gift baskets, and other items of tangible personal property over the Internet. The company does not maintain any...more

Global Tax News: India announces fundamental changes to the India-Mauritius double tax treaty

The Government of India announced in a press release dated May 10, 2016 that Mauritius and India have signed a protocol amending the agreement for avoidance of double taxation with Mauritius. The text of the protocol is...more

Investing in India? Take a Look at the Amended India-Mauritius Tax Treaty Before You Do

On May 10, 2016, India and Mauritius signed a protocol amending the India-Mauritius double income tax treaty that would, among other things, permit India to tax a Mauritian resident on capital gains arising from the sale of...more

Potential tax consequences of Brexit from a German perspective

On 23 June, the UK is holding a referendum to decide whether it should leave or remain in the European Union. A vote to leave the EU (the so-called Brexit) would not only have repercussions from a tax perspective for the UK....more

India-Mauritius Tax Treaty Amended

The amendments are a result of long-drawn negotiations between the two countries. India and Mauritius signed a Protocol on May 10 to amend the India-Mauritius double taxation avoidance treaty. The Protocol grants India...more

Recent Indian Tax Treaty Changes Affecting Nonresident Investments into India - Termination of Capital Gains Exemption under the...

India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more

Weekly Web Wrap-Up

Welcome to Sheppard Mullin’s Weekly Web Wrap-Up, a quick list of the past week’s top news in the social media, gaming, and virtual goods and currencies industries curated by Social Media & Games Team. Here are some of the...more

Treasury Proposes Fundamental New Limitations on Related Party Lending Transactions – With Retroactive Effect!

The U.S. Treasury Department has very recently and unexpectedly released significant guidance that promises, if finalized, to fundamentally limit the circumstances under which related corporations (and, in some cases,...more

Amendments to real estate legislation - Quarter 1 of 2016

Amendments to federal laws - Federal Law No. 431-FZ dated 30 December 2015 “On Geodesics, Cartography and Spatial Data and on Amendments to Certain Legislative Acts of the Russian Federation” The law under...more

Development of the tax practice of the “beneficial owner” concept

On March 3, 2016 the Commercial Court of Moscow rendered a decision on case No. ?40-241361/15 (the “Decision”) under the claim of BANK INTEZA joint stock company (the “Russian Company”). The decision contains a number of...more

GST to be removed from Bitcoin transactions – how best to fix the "double taxing" of digital currency?

The Treasurer, Scott Morrison, recently announced that the Government is committed to working with the FinTech industry on legislative solutions for the GST "double tax" issues that can arise on domestic transactions...more

Group Seeks Relief For U.S. Citizens With RESP and TFSA Accounts

In a letter dated March 4, 2016, the American Chamber of Commerce in Canada (“AmCham Canada”) requested that the United States Department of the Treasury (“Treasury”) provide various forms of tax relief to U.S. and Canadian...more

UK Budget 2016: Finance

From April 2017, the UK government is to cap the amount of corporation tax relief for interest to 30% of taxable earnings in the UK or the net interest to earnings ratio for the worldwide group. This is subject to a threshold...more

European M+A News, Winter 2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

White & Case ECB News – Issue 2, 2015: 60 seconds around the globe – ECB News Issue 2, 2015

China - Changes to Employee contribution rates for work related injury insurance and maternity insurance - As of 1 October 2015, employer contribution rates for injury-at-work insurance and maternity insurance have...more

Kyiv Tax Alert (Ukrainian)

On 11 December 2015 the representatives of the governments of Ukraine and Cyprus have signed the Protocol on amending the Convention between the Government of Ukraine and the Government of Cyprus on the Avoidance of Double...more

Kyiv Tax Alert - Amendments to the Convention between the Government of Ukraine and the Government of Cyprus on the Avoidance of...

On 11 December 2015 the representatives of the governments of Ukraine and Cyprus have signed the Protocol on amending the Convention between the Government of Ukraine and the Government of Cyprus on the Avoidance of Double...more

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