Canada: ConocoPhillips: FCA Confirms Tax Court’s Jurisdiction To Determine Questions Of Timing And The Validity Of A Notice Of Objection

In ConocoPhillips Canada Resources Corp. v. The Queen (2014 FCA 297), the Federal Court of Appeal overturned aFederal Court decision (2013 FC 1192) and dismissed an application for judicial review by the taxpayer finding that the Federal Court lacked jurisdiction in this case.

ConocoPhillips had commenced an application for judicial review as a result of a dispute between the CRA about whether a Notice of Reassessment had been validly sent to the taxpayer.  The CRA alleged that it […]

By |January 16th, 2015|

Overview Of Real Estate Investments In Italy

Investment Entities
Real estate investments in Italy are mainly carried out via one (or a combination) of the following types of investment vehicles.
Real Estate Companies
Real estate companies are special purpose vehicles carrying out the purchase, management, leasing, building, and sale of Italian real estate assets (società immobiliari). Real estate companies are generally formed as limited liability companies (società a responsabilità limitata, “S.r.l.”) or joint-stock companies (società per azioni, “S.p.A.”).

With a few exceptions, real estate companies […]

By |January 16th, 2015|

United States: IRS Issues Additional ACA Requirements For Tax-Exempt Hospitals

On December 31, 2014, the IRS published final regulations providing guidance on the community health needs assessment and financial assistance policy requirements for charitable hospitals under the ACA. The regulations address the entities that must meet these requirements, related reporting obligations, and the consequences for failing to satisfy these ACA requirements. The regulations apply to taxable years beginning one year after December 29, 2014.

By |January 15th, 2015|