United States: Oregon Tax Court Holds Cable Company’s Video Services Subject

The Oregon Tax Court has held that an out-of-state cable company’s video services constituted “broadcasting” and were subject to the special apportionment provisions for interstate broadcasters for purposes of Oregon corporate excise (income) tax.1 However, the cable company’s Internet and telephone services were not considered to be broadcasting subject to the special apportionment rules. Under Oregon law, service revenue generally is apportioned using a cost of performance (COP) methodology, but interstate broadcasters were required […]

By |February 16th, 2015|

Canada: GST/HST And QST On Management Fee Distributions Or Rebates

The Tax Court of Canada’s recent decision in Invesco Canada Ltd. v. The Queen1 confirms that GST applies only to the net management fees paid by a mutual fund trust to its fund manager where the normal management fees are reduced, at the discretion of the manager, as a special distribution paid directly by the mutual fund trust to “large investors” such as pension funds and other sophisticated investors.
Facts and background
Invesco Canada Ltd. (“Appellant”) […]

By |February 13th, 2015|

Former Wegelin Banker Reportedly Arrested On U.S. Warrant In Germany

Multiple outlets are reporting that on February 2, 2015, three years after his indictment in the Southern District of New York, Swiss banker Roger Keller was arrested at the Frankfurt airport. On January 3, 2012, the U.S. Attorney for the Southern District of New York indicted Wegelin Bank, Keller, Urs Frei, and Michael Berlinka, for assisting customers in evading taxes. In 2013, Wegelin pleaded guilty and agreed to cease operations. Keller awaits extradition to […]

By |February 13th, 2015|