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Wells Fargo Victory Broadens Interest Netting For Merged Corporations
The United States Court of Federal Claims recently granted partial-summary judgment to Wells Fargo & Company in a significant interest netting case.
United States
16 Jul 2014
Rep. Campís Proposal Would Affect Tax Benefits For Renewable Energy Property
On February 26, 2014, a discussion draft of the Tax Reform Act of 2014 was released by House Ways and Means Committee Chairman Dave Camp.
United States
11 Mar 2014
Revenue Procedure 2014-12: IRS Follow-Up To Historic Boardwalk
On December 30, 2013, the Internal Revenue Service (the "IRS") released Revenue Procedure 2014-12 (the "Revenue Procedure"), describing a "safe harbor" for the allocation among partners of rehabilitation credits under section 47 of the Internal Revenue Code of 1986, as amended (the "Code").
United States
7 Jan 2014
IRS Notice 2013-29: What It Means To "Begin Construction"
The Internal Revenue Service has recently published Notice 2013-29, providing guidance on what it means to "begin construction" under the Act.
United States
23 Apr 2013
FATCA 3.0 For Funds And Securitization Vehicles
The U.S. Internal Revenue Service has recently released final regulations under the so-called "FATCA" provisions found in Section 1471 through 1474 of the U.S. Internal Revenue Code.
United States
27 Feb 2013
Renewable Energy Tax Provisions In The Fiscal Cliff Legislation - The "American Taxpayer Relief Act Of 2012"
A discussion on the recently approved "American Taxpayer Relief Act of 2012".
United States
7 Feb 2013
Indian Tax Department Challenges Recent Supreme Court Holding That Offshore Indirect Investment Transaction Is Not Subject To Withholding Tax
The hottest tax case in India has not been resolved just yet. On February 17, 2012, the Indian Tax Department ("ITD") filed a review petition challenging the very recent Supreme Court of India decision in Vodafone International Holdings B.V ("Vodafone BV") v. Union of India & Anr.
7 Mar 2012
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