United States: The Changing Landscape Of Charitable Tax Exemption In Pennsylvania

Introduction
On February 17, 2015, the Pennsylvania Senate passed a bill that could have far reaching implications for all Pennsylvania nonprofit charitable organizations. The bill, S.B. 4, is a proposal to amend the Pennsylvania Constitution to give the General Assembly the authority to determine the qualification standards for so-called “institutions of purely public charity.” To effect such an amendment, the bill must be passed in two consecutive legislative sessions before being approved by Pennsylvania voters […]

By |February 20th, 2015|

United States: ALJ: New York NOL Deduction Does Not Apply When Tax Is Not Paid On Income Base

A New York State Division of Tax Appeals administrative law judge (ALJ) recently determined that a banking corporation was not required to hypothetically use a net operating loss (NOL) deduction to decrease its entire net income in a year in which its banking corporation franchise tax liability under Article 32 of the New York Tax Law (bank tax) was not measured by the entire net income base.  Matter of TD Holdings II, Inc., DTA […]

By |February 19th, 2015|

BEPS Targets Commonly Used Canada-U.S. Hybrid Structures

Davies Partner Abraham Leitner discusses the impact of the OECD’s recommendations on a number of structures commonly seen in Canada-U.S. cross-border financings.

“The introduction of yet another set of domestic hybrid rules, such as the ones proposed by the hybrid arrangement report, would make the planning in this area only more dangerous,” Mr. Leitner writes.

Read the full article.

By |February 19th, 2015|