Searching Content indexed under Tax Authorities by WilmerHale ordered by Published Date Descending.
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USTR Launches Section 301 Probe Of France's Digital Services Tax
The Office of the U.S. Trade Representative ("USTR") announced on July 10 the initiation of an investigation under Section 301 of the Trade Act of 1974 into France's digital services tax ("DST").
United States
17 Jul 2019
Revaluations In Upper-Tier Partnerships — An Alternative Approach
Section 704(c)(1)(A) is a seemingly modest provision.
United States
5 Jul 2019
The Section 4960 Excise Tax: Application To Tax-Exempt And Affiliated Taxable Entities
Federal tax law changes enacted with the Tax Cuts and Jobs Act of 2017 may require tax-exempt organizations to reevaluate their compensation practices, particularly with respect to employee severance.
United States
6 Jun 2019
In Case You Missed It: Launch Links - Week of April 22, 2018
Some interesting links we found across the web this week:
United States
30 Apr 2018
Tax Act: New Laws Affecting Tax-Exempt Organizations
The Tax Act contains a number of provisions that significantly affect tax-exempt organizations, in some cases to degrees not seen in decades.
United States
15 Jan 2018
Tax Cuts And Jobs Act Summary
On December 22, 2017, President Trump signed sweeping tax reform legislation (H.R. 1) into law. The new law, commonly known as the Tax Cuts and Jobs Act (the "Tax Act"), makes significant changes ...
United States
15 Jan 2018
German Cum/Ex-Trades: Enhanced Risks And Industry-Wide Challenges
The German and international financial industries and their advisors have come under new pressure to investigate so-called 'cum/ex' trades conducted between 2000 and 2012.
8 Mar 2016
Tax Matters Facing Foreign Startups Who Want to Come to the US (Video Content)
The tax structure for a foreign company coming to the US is essential to making sure the transaction is tax-free.
United States
8 Mar 2016
IRS Issues Guidance On The Applicability Of Section 162(m) To CFO Compensation
The IRS recently informally revised its guidance regarding which officers of public companies must be considered when determining the compensation deduction limitation of Section 162(m) of the Internal Revenue Code and applied the limitation to CFOs of certain smaller public companies.
United States
23 Nov 2015
Second Circuit Clarifies Common Legal Interest And Work Product Doctrines For Material Shared Among Transacting Parties
The U.S. Court of Appeals for the Second Circuit recently ruled that the "common interest" doctrine protects legal and tax liability analysis prepared for a client and subsequently shared with a consortium of banks providing financing for the client.
United States
16 Nov 2015
Tax Time Alert: Key Things To Know About Founders Preferred Stock
As you gather and review tax papers for your return, be sure to inform your accountant if you hold founders’ preferred stock, or if you sold a block of it in 2014.
United States
13 Apr 2015
Final Section 162(m) Regulations Clarify Transition Rules For Newly Public Companies And The Per Participant Limit Requirement
Following the issuance of proposed regulations in June 2011, the Internal Revenue Service issued final regulations on March 30, 2015 clarifying certain exceptions to the compensation deduction limitation imposed by Section 162(m) of the Internal Revenue Code.
United States
2 Apr 2015
IRS Extends Timelines Under FATCA And Provides Further Guidance With Regards To Intergovernmental Agreements
On July 12, 2013, the Internal Revenue Service (IRS) issued Notice 2013-43 (the Notice), which modifies the timelines for the implementation of certain requirements under Sections 1471 through 1474 of the Internal Revenue Code (commonly referred to as the Foreign Account Tax Compliance Act or FATCA).
United States
15 Jul 2013
Massachusetts Governor's Tax Proposals for Businesses
The proposed 2014 Massachusetts budget submitted by Governor Deval Patrick includes not only provisions that eliminate many individual tax exemptions and increase the individual income tax rate from 5.25% to 6.25%, but also significant changes to the tax laws affecting businesses.
United States
13 Apr 2013
Massachusetts DOR Issues Draft Directive on "Cloud Computing"
The application of sales and use taxes (collectively referred to herein as the "sales tax") to services and products provided in what is called the "cloud" (often referred to as "cloud computing" or "Software-as-a-Service") is a complicated issue which has not been dealt with by many states.
United States
21 Feb 2013
$150 Million Of Credits Available Under Phase II Of Qualifying Advanced Energy Project Credit Program
Notice 2013-12 provides the parameters of Phase II of the Program. As with Phase I, the IRS will consider a project under Phase II only if the DOE provides a recommendation and ranking for the project.
United States
14 Feb 2013
Medical Device Excise Tax Set To Become Effective January 1, 2013
Beginning January 1, 2013, a 2.3 percent excise tax will be imposed on sales of "taxable medical devices" by manufacturers and importers.
United States
20 Dec 2012
IRS Extends Timeline For Due Diligence And Other Requirements Under FATCA - Implications For Private Investment Funds
On October 24, 2012, the Internal Revenue Service ("IRS") issued Announcement 2012-42 (the "Announcement"), which further extends the timeline for completion of certain due diligence and other requirements and provides additional guidance concerning gross proceeds withholding and the status of certain instruments as grandfathered obligations under Sections 1471 through 1474 of the Internal Revenue Code (commonly referred to as the "Foreign Account Tax Compliance Act" or "FATCA").
United States
1 Nov 2012
FBAR Deadline Is June 29, 2012; IRS Form 8938 May Also Be Required
The June 29, 2012 filing deadline for the 2011 Report of Foreign Bank and Financial Accounts (FBAR) is fast approaching, except for those covered by the limited exception described below.
United States
11 Jun 2012
Impact Of Proposed FATCA Regulations On Private Investment Funds
On February 8, 2012, the Internal Revenue Service ("IRS") issued proposed Treasury Regulations (the "Proposed Regulations") under Sections 1471 through 1474 of the Internal Revenue Code (commonly referred to as the "Foreign Account Tax Compliance Act" or "FATCA").
United States
29 Feb 2012
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