The IRS recently issued Notice 2014-4 (the “Notice”), which provides interim guidance for Type III supporting organizations seeking to qualify as functionally integrated by supporting governmental organizations.
After much discussion and commentary echoing for months from both sides of the border, the United States and Canada executed, on February 5, 2014, an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act.
Your Appraisal or Their Appraisal? Applying for Federal Reimbursement May Destroy an Appraisal’s Protected Status
In a recent decision by the Appellate Division, Third Department, Lerner v. New York, the Court confirmed that documents prepared in anticipation of litigation, including appraisal reports, would lose their protection as “work-product” if disclosed to a third party.
U.S. Based Parent Corporations with Foreign Branch Operations Need to Take into Account Potential Application of the Overall Foreign and Domestic Loss Rules
For U.S. taxpayers planning to engage in business operations in foreign countries, especially in start-up type situations, consideration must be given as to what are the potential tax consequences, including timing differences, for reporting built-in losses and anticipated foreign losses from operations overseas.
It was reported this morning that a State District Court in Travis County, Texas, decided that the sale of a “wellbore video” was the sale of a nontaxable service rather than taxable tangible personal property.
On February 5, 2014, the BC government announced that it is unlikely to release the detailed tax regime for the province’s proposed liquefied natural gas (LNG) sector before the fall legislative session.
On December 17, 2013, the United States District Court for the Northern District of Georgia issued its decision in United States v. Morris Legal Group, LLC, 113 AFTR 2d, 2014-XXXX (D.C. Georgia).