United States: Banking Corporation Not Required To Hypothetically Use New York NOL Deduction When Tax Is Paid On Asset Base

A New York State Division of Tax Appeals administrative law judge (ALJ) recently ruled in Matter of TD Holdings II, Inc., DTA No. 825329 (N.Y. Div. Tax App. Jan. 22, 2015), that a banking corporation is 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 Tax Law (bank tax) is […]

By |February 11th, 2015|

United States: Cooperative Hospital Service Organizations: A Hospital Joint Venture Option

Cooperative Hospital Service Organizations (CHSOs) are organizations that are available for hospitals considering certain types of joint ventures with other hospitals. If the terms for their use strictly meet the regulatory requirements, CHSOs can provide both tax exemption and Antikickback Statute Safe Harbor protection for such joint ventures.

CHSOs must be organized and operated on a cooperative basis and their activities must be limited to the performance, on a centralized basis, of one or more […]

By |February 10th, 2015|

Zambia Mining Tax Amendments

The far-reaching amendments to Zambia’s mining tax regime announced by Finance Minister Alexander Chikwanda in his 2015 Budget Speech on 10 October 2014 and presented to Parliament on 28 November 2014, were passed by Parliament on 17 December 2014.

With effect from 1 January 2015 open cast and underground mining operations are exempt from corporate income tax, but will be subject to a final 8% mining royalty in respect of underground mining operations and a […]

By |February 10th, 2015|