United States: 2014 May Be The Last Year For Valuable “Tax Extenders”

Last week, President Obama threatened to veto an agreement between Senate Democrats and House Republicans on a collection of tax breaks known as “tax extenders.” The deal would have been a huge win for manufacturing, because it would have extended or made permanent a number of tax breaks that directly benefit manufacturers. Now, the likely result is a one-year extension for incentives that lapsed in 2013. As a result of this breakdown in negotiations, […]

By |December 4th, 2014|

United States: California Tax Developments (3rd Quarter 2014)

Case Updates

Court finds ownership of LLC membership interest does not constitute doing business in California

On November 14, the Fresno County Superior Court determined that Swart, an Iowa-based corporation with a tangential investment in California, did not meet the statutory requirement for doing business in California.1 Swart invested $50,000, amounting to approximately 0.02% ownership, in a California LLC. Swart had no physical presence in California; it had no employees in California, and did not own […]

By |December 4th, 2014|

Taxation Of Multinationals – UK Government Announcements Related To The G20/OECD Base Erosion and Profit Shifting Initiative

The Chancellor reaffirmed the Government’s continued support for the OECD’s work on base erosion and profit shifting (BEPS) and modernisation of the international framework for taxing multinational companies.

Measures in relation to three specific areas are announced – a consultation on hybrid mismatches and the introduction of the OECD’s proposals into UK legislation, a commitment to introduce country-by-county reporting of information to tax authorities for UK multinationals and a newly-announced ‘diverted profits tax’ to counter […]

By |December 3rd, 2014|