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This edition of International Tax News includes updates on the OECD BEPS initiative and EU State aid.
Analysis and insights into state and local tax developments
German legislative committees propose BEPS-related tax provisions. Among these, the BEPS-related hybrid mismatch rule
US Customs & Border Protection enacted changes to its Focused Assessment Audit Program.
This bulletin considers how tax authorities in many countries are streamlining tax processes for cross-border employees.
Angola—Transfer pricing documentation for 'large taxpayers' due in 2015.
Our October edition features: The IRS intends to issue regulations under section 7874 to address 'inversions.'
Argentina: Supreme Court dismisses case originating from a transfer pricing adjustment established by Tax Authorities
Health plans must apply for a health plan ID by November 5, and must schedule payment of the TRP fee by November 15.
Effective October 24, 2014, A-3213 enacts significant changes to the state's Grow New Jersey tax credit program.
The European Commission takes new action regarding State aid rules, this time involving Spain.
During its meeting on October 22, 2014, the FASB agreed to issue an exposure draft related to two tax accounting topics.
Discusses recent cases on substantiating business use of aircraft and application of passive activity rules to leases.
Finance Bill 2014 was published yesterday and it clarified some of the changes announced in Budget 2015.
New IRS guidance extends the allocation method provided by IDD #5 regarding mixed service costs.
Three NJ bills target domestic corporations that become foreign-incorporated corporations.
Accounting Methods Spotlight: Recent legislative developments and IRS guidance impacting tax accounting method issues
PwC's Global Watch newsletter addresses important issues around income and social tax, legislation, changes in employment rules, treaties, rulings, etc. Each Global Watch is classified by the country or territory to which it pertains.
Future changes to Japan gift and inheritance taxes are fast approaching that will increase the tax rates.
An energy company was required to use South Carolina's three-factor apportionment formula applicable to manufacturers.
The IRS will not contest a restaurant's use of a facts-and-circumstances method to allocated kitchen labor to COGS
Amendments to the Australian thin capitalization rules have been granted Royal Assent.
Multinational reorganizations can bring about a host of employee mobility issues – consider employment frameworks early.
Bombay High Court issues ruling in the context of the Writ Petition filed by Vodafone India Services Private Limited.
2014-2015 IRS/Treasury guidance plan includes projects that will materially impact partnerships and partners
FASB has added a project to improve accounting for share-based payments that may impact stock compensation accounting.
Ireland announced its 2015 budget yesterday ending a series of austerity budgets and beginning certain tax reforms.
IRS allows taxpayers who are beneficiaries of certain Canadian retirement plans to obtain favourable US tax treatment.
The Irish Finance Minister announced the Irish Budget 2015 and published A Road Map for Ireland's Tax Competitiveness
Australia Government announcement: Taxation of employee share schemes.
The Nevada margin tax initiative will appear on the November 4, 2014 ballot. Proceeds from the tax would be allocated to
With analysis and insight on policy changes around the world, these bulletins help you stay up-to-date with the latest developments and explain what these changes mean for you and your business.
This briefing on EU State aid answers common questions and answers
Ireland has made changes to its employment permits regime effective October 1, 2014.
For 2015 Texas Franchise Tax reports, the rate is 0.475% for retailers/wholesalers and 0.95% for all other taxpayers.
Louisiana tax amnesty program begins October 15, 2014.
The OECD published on 16 September 2014 a report on hybrid mismatches that was was approved by G20 Finance Ministers.
FASB adds stock compensation tax accounting topics to its agenda (October 2014)
In Notice 2014-58, the Service clarifies previously unanswered questions regarding the definition of 'transaction'
Companies may consider accounting method changes to meet cash-tax planning goals or estimated payment requirements.
This issue of PwC's European Customs & International Trade Communiqué covers EU sanctions against Russia and more.
Final regulations on 'excepted benefits' under ACA provide clarity for dental, vision and employee assistance programs.
The California Documentary Transfer Tax may apply to legal entity interest transfers if a 'change of ownership' results.
In this release we discuss a variety of global accounting, reporting and tax law developments
This September 2014 issue of PwC's India Indirect Tax Newsletter provides news on important legislative developments.
The Tax Court ruled that much of the comp paid to a CEO was unreasonable and didn't qualify for the research credit.
VAT News highlights: ECJ addresses VAT groups, UK MOSS scheme, priority refunds in Italy and IMMEX companies in Mexico.
European Commission to examine Gibraltar's tax rulings practice from the perspective of European Union State aid rules.
The Polish President has signed a bill amending Polish tax laws in significant ways for US MNCs
After six months of debate in the Chilean Congress, the country's significant tax reform was published Sept. 29.
We highlight significant state and local tax developments that occurred from June to September 2014.
International Tax News is a monthly publication that offers updates and analysis on international tax developments worldwide.
This newsletter covers international tax issues including legislative changes, case law and treaty changes.
Tax policy bulletins provide analysis and insight on policy changes around the world and what these changes mean for you.
Products shipped to Illinois to accommodate further shipping to a predetermined country are not IL destination sales.
Combined returns may be filed without substantial intercorporate transactions when necessary to avoid distortion.
Cencast employment tax decision impact on production companies and employees, REIT rulings and CA film tax credit.
EU Commission's opening decisions in the formal investigations into transfer pricing agreements in Ireland, Luxembourg.
Recently, the OECD published reports on the BEPS Action Plan items dealing with topics relevant to the PLS industry.
Discusses aircraft related items in the current IRS business plan and the requirement to use the SIFL rules consistently.
Accounting Methods Spotlight: New developments provide guidance on tax accounting method issues.
Turkey makes legislation changes affecting employers and assignees.
This Month: The IRS Business Plan, lists upcoming guidance that will affect corporate & partnership transactions.
Switzerland published for consultation the Corporate Tax Reform III draft legislative text.
France: Final version of the 'light' transfer pricing documentation form released
Treasury and the IRS recently issued Notice 2014-52 addressing certain cross-border business combination transactions.
Immigration policy continues to change in countries around the world. Trends indicate an increase in the enactment of immigration legislation, such as a new European Union (EU) Directive on Intra-Corporate Transfers (ICTs).
California expands and extends its film credit.
The U.S. Court of Appeals for the Federal Circuit Found Trek Leather's President Liable for Customs Penalties.
IRS Issues Final Regulations under 162(m)(6) for Covered Health Insurance Providers.
The IRS guidance allows rollover of the after-tax portion of a retirement plan distribution directly into a Roth IRA.
Recently released instructions to the 2014 Form 1042-S clarify FATCA reporting requirements for US premiums.
OECD guidance seeks to provide coherent and consistent framework under which MNEs should prepare global TP documentation.
ITFA temporarily extended. Pres. Obama signed provisions extending the Internet Tax Freedom Act (ITFA) through Dec. 11.
A pre-filing agreement (PFA) allows a taxpayer to obtain certainty on an issue before filing its return.
The decision provides clarity on the controversial issue of the deductibility of interest on related-party loans.
Members of the ACT provided background and context regarding the recommendations regarding unrelated business income tax.
The IRS on August 14 issued final regs that restate and clarify the computation of certain ending inventory values.
This month's issue addresses recent tax and legal changes in various jurisdictions.
The Notice addresses certain cross-border business combination transactions, termed 'inversions.'
New Jersey announced a closing agreement initiative that runs through November 17, 2014.
OECD: Key elements of the work on intangibles have not been finalised yet and thus need to be viewed as interim guidance.
Colombia has reintroduced an equity/net-assets tax for companies and individuals.
California established application periods for $150 million of California Competes Tax Credits.
IRS issues final regulations on market rate of return issues for cash balance and other hybrid plans.
The main UK political parties have committed to further devolution.
Rev. Proc. 2014-54 provides rules for accounting method changes related to tangible property dispositions.
The House today passed HR, which would simplify and make permanent the research credit.
An Oregon regulation provides guidance regarding tax haven entities.
Executives' returns may be impacted if IRS finds errors in exam of deferred compensation.
This Bulletin summarises some of the OECD's agreed recommendations for changing the international tax rules.
A Missouri taxpayer could not carry over prior-year separate return NOLs to a subsequent consolidated return year.
IRS guidance on HATFA gives defined benefit plan sponsors until December 31, 2014 to make certain elections.
FASB discusses income tax accounting for stock compensation (September 2014).
IRS provides annual domestic asset & liability percentages for foreign insurance companies.
The Michigan legislature passed a bill retroactively repealing the Multistate Tax Compact effective January 1, 2008.
Schumer bill would impose further restrictions on cross-border merger transactions.
India makes amendments to social security scheme effective September 1, 2014.
The Spanish government has sent amended versions of major tax reform bills to Parliament for approval.
IRS releases forms, instructions for employers and healthcare providers to comply with the Affordable Care Act.
IRS concludes that life insurance company's passive investment activities qualify as insurance business.
When determining the tax treatment of False Claims Act penalties, a court may look beyond parties' tax characterization.
VAT News highlights: ECJ addresses leased cars, B2C 2015 VAT changes, and new China policy for mergers and acquisitions.
The 2014-2015 Priority Guidance Plan includes seven items specific to the insurance industry.
IRS has issued its 2014-15 business plan listing planned guidance on retirement, ACA and other employee benefis issues.
China SAT Notice covers characteristics of suspicious intra-group outbound service and royalty charges needing attention.
New York releases Excelsior Jobs guidance, readopts START-UP emergency rules, and proposes to extend Brownfield Program.
Our Tax Controversy and Regulatory Services newsletters provide analysis on significant tax controversy issues and related developments from around the world.
Delaware – September deadline looms for unclaimed property VDA program (Administered through the Secretary of State).
The Mauritius and Kenya parliaments ratified the double-taxation treaty between Mauritius and Kenya on May 23, 2014.
Under the Sec. 263A regs, taxpayers may allocate some royalties to COGS or between prop. sold and ending inventory.
Comments invited on proposed update to Singapore Transfer Pricing Guidelines on transfer pricing documentation.
There are areas where it was not appropriate for UK CDOT to exactly mirror US FATCA due to differences in context.
50% of an offshore company's share value derived from assets located in India qualifies as 'substantially' for purposes.
The Post-Implementation Review Report recently issued on FAS 123(R) finds certain elements difficult or costly to apply.
2014-15 Priority Guidance Plan includes international tax guidance projects that collectively will affect all companies.
Mexico Tax Authority's new reporting requirement for VAT-certified IMMEX companies.
The August 2014 edition of This Month in M&A featuring tax planning, current developments, and other topics.
A totalization agreement between India and Sweden is effective as from August 1, 2014.
The state's separate reporting regime did not bar taxing an intangible holding company's IRC § 311(b) gain.
A Texas court of appeals held that mining and extraction costs do not qualify for the manufacturing exemption.
Illinois enacts click-through sales and use tax nexus legislation.
This month's issue addresses recent tax and legal changes in the United Kingdom and Belgium.
The Indiana Supreme Court held that a taxpayer may not deduct foreign source dividends when calculating Indiana NOLs.
New SIFL rates for second half of 2014 and last call for 2013 bonus depreciation.
New FASB guidance, IRS and Court rulings address tax accounting method issues.
Tax Policy Bulletins provide analysis and insight on policy changes around the world.
In our August 2014 issue, we explore state and local tax issues affecting retailers.
International Tax News helps multinational organisations keep up with international tax developments worldwide.
Accounting Methods Spotlight: New legislative developments and rulings provide guidance on tax accounting method issues.
Tax issues related to personal use of company planes by retirees and a federal air transportation excise tax update.
Our July edition features the Tax Court's treatment of goodwill used by corporation as owned by sole shareholder.
This issue addresses recent tax and legal changes in Australia, China, Hong Kong, India and Singapore.
Latest Developments in EU International Trade - July 2014.
Global companies investing in the United States face unique opportunities and challenges. Doing business in the US reviews the key tax issues and provides insights to help investors navigate the US business environment.
Global Green Policy Insights is a bimonthly update on the latest developments in environmental taxes, regulations, and other "green" policies around the world. Written by PwC specialists around the world, they provide timely updates on new tax incentives, credits, and policy issues of interest to multinational organisations.
In this release we discuss a variety of global accounting, reporting and tax law in the quarter ended 30 June 2014.
The OECD BEPS recommendations require careful examination of potential EU law issues.
Court ruling on Sections 465 & 469/House Ways and Means Committee approves permanent extension of bonus depreciation.
Spectrum auction, Favorable REIT rulings for EMC companies, New York State Corporate Tax Reform.
Accounting Methods Spotlight: New developments impacting tax accounting methods.
This Month in M&A has articles authored by members of the NTS M&A Group regarding tax planning & current developments.
For foreign-based multinational corporations (MNCs) doing business in the United States, the amount of customs duties paid on goods entering the U.S. often is not a top-level consideration. However, many of those companies might be leaving money on the table by paying more in customs duties than is necessary.
This issue addresses recent tax and legal changes in Australia, China, Signapore, & United Kingdom.
IPCC's new climate change report; EU's new State aid guidelines; Highlights of country-specific developments
Joel Walters, leader of the U.S. inbound tax practice and the global communications tax practice at PwC shares insight on the overall tax environment, public perception of multinational companies and the OECD/G-20 BEPS project.
Assessing Tax 2014 provides a detailed analysis of tax rate metrics for 324 companies and highlights tax trends for aerospace and defense, automotive, chemicals, engineering and construction, industrial manufacturing and metals, and transportation and logistics companies. This issue includes a special report on the surge in international tax controversy.
What tax issues are potentially affecting companies investing in the USA today?
VAT News highlights: AG opinion on VAT group services and branch offices, VAT rate changes in Luxembourg, Poland and Crimea, and JCT on electronic supplies of services
This newsletter includes tax planning, current developments, and other corporate and passthrough transaction topics.
May 2014 Aircraft Club Newsletter: Courts in Nevada and Illinois have ruled in two recent court cases on the application of state use tax to corporate aircraft.
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These alerts provide analysis of the impact of major transfer pricing, tax, and related developments within hours of the news breaking, authored by PwC professionals around the world. Each alert is classified by the country or territory to which it pertains.
Paul DeNard recently spoke with Tax Analysts about his career, the interaction between the domestic and international sides of Large Business & International tax, and his thoughts on the audit selection and personnel challenges facing the Service.
The IRS on August 14 released final regulations regarding disposition of tangible depreciable property.
Draft IRS forms help insurers and employers offering health coverage as they face new health reform reporting rules.
A new law in Puerto Rico offers individuals unique incentive opportunities during a limited time period.
Tax return compliance and due diligence considerations for S corporations.
On August 9, 2014, the Chilean Executive Branch proposed several amendments to the tax reform bill.
BCBS reorganization ruling includes representation regarding 9010(a) health insurer fee.
A draft law adopted by the Russian State Duma can significantly change the procedure for employing CIS nationals.
Key elections and accounting methods taxpayers should consider for 2013 returns.
Russia introduces new requirements for notifying authorities about acquiring foreign citizenship or residency permit.
FASB adds income tax accounting topics to its agenda (August 2014)
China updated its new visa policies for multinational corporations aimed at attracting foreign investment to Shanghai.
Unless action is taken, IRS processing changes could affect partner refunds.
The IRS today released final regulations under Section 168 regarding the disposition of tangible depreciable property.
The period for claiming research credits for the 2010 tax year will close on Sept. 15, 2010, for many taxpayers.
Recent Board of Review case applies a wide variety of factors to determine the source of director fees in Hong Kong.
The French tax authorities have released final guidelines regarding legislation targeting hybrid mismatch arrangements.
Notice 2014-46 provides additional guidance on the begun construction test and the Section 45 production tax credit.
CBP have increased their scrutiny of imports from Canada.
Health insurers and self-insured group health plans must complete required reinsurance forms by November 15, 2014.
The UK's tax authority has revoked key guidance on the interaction of loans and the remittance basis of taxation.
Congress amends the pension smoothing provisions of MAP-21 to delay the phase-down of the interest rate corridor.
Important tax developments that could affect US MNCs doing business in Central or Eastern Europe
Latest Customs and Foreign Trade Policy News from PwC India.
Financial executives at major organizations are increasingly collaborating with their tax departments and monitoring the expanded use of enforcement actions by the Internal Revenue Service under stricter guidelines for complying with information document requests (IDRs).
This issue addresses recent tax and legislative changes in New Zealand, South Africa & Turkey.
OECD BEPS action 1 on the digital economy - some thoughts on EU State aid rules.
Accounting Methods Spotlight: New guidance on tax accounting method issues
VAT News highlights: CJEU addresses lump sum payments by healthcare insurers, B2C 2015 VAT changes, and proposed changes to the Japanese Consumption Tax system.
In this release we discuss a variety of global accounting, reporting and tax law developments in the first quarter of 2014, and the related tax accounting considerations.
This issue addresses recent tax and legislative changes in Australia, Chile, China, France, Italy, United Kingdom and United States
The PwC Retail and Consumer Roundup - Recent state and local tax issues affecting retailers (April 2014).
This issue features principles of Commissioner's Discretionary Rule applied for taxpayer favorable result on noncapital, nondedectible intercompany loss, among others
PwC's 2014 year-end guide to tax and wealth management offers guidance for strategic tax planning, managing your portfolio, charitable giving, estate and gift planning, business succession planning and other topics.
Rev. Proc. 2014-1 and other IRS rulings provide guidance on tax accounting issues
The April issues discusses Chairman Camp's tax reform proposals and the methods a taxpayer may employ to allocate expenses to personal entertainment flights taken.
Global Information Reporting: OECD publishes long anticipated Commentary on Common Reporting Standard.
The IRS recently published final regulations allowing filers of certain information returns to use truncated TINs.
Wyden criticizes Treasury and IRS for failure to close hedge fund 'loophole' that uses offshore insurance companies.
The IRS recently released the instructions for Form W-8BEN-E for complying with FATCA.
According to our 2014 Assessing tax, average ETRs over the last three years have continued to edge upward.
IRS Notice 2014-39 clarifies important questions with regards to Treasury Section 1603 grants subject to sequestration.
Support payments made by manufacturers under 'facility image upgrade programs' are includible in gross income.
The EPA released proposed regulations under the Clean Air Act that would for the first time set carbon emissions reduction targets for existing US electric power plants.
FATCA not only impacts the financial services sector, but many entities outside of the traditional financial services sector with operations in and outside of the US.
With the credits and incentives landscape always changing, this publication on C&I developments will help you stay abreast of issues that may affect your business.
In Revenue Ruling 2014-15, the IRS holds that an arrangement entered into to provide health benefits for retirees of a single employer qualifies as insurance.
The US Treasury and IRS announced in Notice 2014-33 that 2014 and 2015 will be a transition period for IRS enforcement and administration with respect to FATCA.
This article highlights the Top 10 accounting method changes for pharmaceutical companies.
FATCA and other recently issued US information reporting regulations are effective immediately or apply beginning July 1, affecting many nonfinancial services entities.
ECJ A-G deems green energy law flawed; China to cut energy intensity further; India to set up environment regulation authority; new Indonesia policy promoting renewables.
IRS expands when a jurisdiction will be treated as having an IGA in effect and extends to May 5, 2014 the time by which FFIs must register with the IRS.
On 3/31/14, the Mississippi governor signed Senate Bill 2933, which provides a new method of apportionment for certain major pharmaceutical and medical product suppliers.
Entertainment, Media, and Communications Tax Newsletter: Vol 21. OECD Action Plan on BEPS and its impact on EMC Companies and more.
Manufacturer not required to capitalize construction support payments made to its retailers.
The IRS issued final regulations relating to the adjustment to inventory costs for the receipt of certain sales-based vendor allowances, specifically vendor 'chargebacks.'
Treasury and the IRS recently released the last substantial package of regulations necessary to implement FATCA, with varying impacts to insurance companies.
The final IRS regulations provide companies the option of allocating capitalizable sales-based royalties to property sold, or between property sold and ending inventory.
House Ways and Means Chairman Dave Camp released the 'Tax Reform Act of 2014' discussion draft, which would affected Insurance companies dramatically.
Treasury and the IRS recently released FATCA amendments and coordinating regulations.
C Corporations may continue to claim enhanced inventory donation deductions
The US Treasury and the IRS released on February 20 final and temporary regulations for FATCA and coordinating regulations for Chapters 3, 4 and 61.
The OECD recently released the Common Reporting Standard to establish a new global standard for automatic exchange of financial account information.
We explore many state and local tax issues affecting retailers, including a Colorado sales tax credit opportunity and Nebraska's proposed daily sales tax remittance law.
In this issue, we concentrate our state tax credits and incentives review to an in-depth exploration of the new and expanded provisions of certain New York credits.
There are many potential tax risks, obligations, and costs associated with moving employees abroad for foreign assignments.
In Validus Reinsurance, Ltd. v. U.S., the DC District Court held that the insurance FET does not apply to certain retrocession arrangements.
This Tax Insight serves as a high-level primer of information reporting and withholding requirements for 2014 and beyond.
Warsaw Climate Change summit (COP19) summary; EU carbon targets for 2030 and a new OECD report; less emphasis on supporting renewables and greater concern over pricing.
Rent-A-Center, Inc. v. Commissioner: A divided Tax Court allows a deduction for premiums paid to a captive insurance company.
PwC's Washington National Tax Services (WNTS) offers a preview of the key tax policy issues facing the Obama Administration and Congress
IRS insight into the Convenience Kit rules and the interpretation of exportation and importation of medical devices and the contract manufacturing rules applied to MDET
Soon to be released 'Common Reporting Standard' promises new FATCA-type obligations around the world.
A listing of PwC webcasts hosted by the US Tax Services team.
Calendar year 2013 has seen considerable activity across the global legislative and regulatory landscapes. We have seen changes to tax laws in several key territories, and certain legislative trends having a significant impact on income tax accounting. These developments, combined with an environment of economic uncertainty, have added to the challenges in accounting for income taxes.
On December 26, 2013, the IRS released the final FFI agreement (to implement FATCA) which contains a number of changes and clarifications to the draft FFI Agreement.
Entertainment. Media & Communications tax newsletter: Section 199 Benefits & Burden determination, communications company tax complexity, goodwill in radio station swaps
For tax years beginning on or after January 1, 2014, retailers will need to evaluate the impact of these new regulations on their businesses.
The IRS concluded that a taxpayer was not entitled to deduct cash bonuses paid to employees until the end of the year in which the bonuses were actually paid
The IRS has issued loss payment patterns and discount factors and salvage discount factors applicable to accident year 2013
Pharmaceutical and Life Sciences ("PLS") companies have traditionally set their transfer pricing strategy by trying to manage the expectations of multiple external stakeholders (regulatory bodies, income tax authorities, and customs authorities) and by staying abreast of industry trends. Nowadays, this task has become even more complex given the recent developments in the international tax and transfer pricing environment and the attention allocated by the media to the international tax practices of multinational companies. This news alert addresses some of the key highlights of the draft documents published by the OECD in the recent months and their anticipated impact for PLS companies.
UN report on climate change; Chile, Portugal, France and Poland renewable energy; developments in the biofuels market; emission in the aviation sector
Numerous income tax accounting matters require the use of estimates, judgments, and other subjective information that can obscure the presentation in the financial statement accounts. Clarifying disclosures can enable users to gain a better understanding of the reporting entity's income tax environment.
The IRS issued a proposed update and revision of the revenue procedure governing advance pricing agreements (APAs).
This decision should be of interest to companies that recently have litigated (or may litigate) issues in the Tax Court.
This release follows the international tax reform discussion draft and tax administration reform discussion draft.
This release, the second in a series of staff tax reform discussion drafts, follows the November 19, 2013 discussion draft on international tax reform.
The changes made by the Updated Directive should allow more taxpayers to streamline the examination of their Section 199 deductions.
The Finance staff international reform discussion draft ('discussion draft') proposes to repeal or modify the current deferral system.
Australian Treasurer has issued a media release regarding the fates of previously announced but unlegislated tax measures.
Summarize the new guidance and the impact on foreign investors doing business with India through an entity located in Cyprus
The IRS issued Notice 2013-69 addressing FFI agreements and related issues under FATCA and accompanying regulations.
On October 22, 2013, the START-UP NY program will create tax-free zones to attract and grow new businesses, and incentivize existing businesses, in New York.
The final regulations are intended to ease the administrative burden and complexity of the segregation rules for loss corporations with small shareholders.
The Japanese government recently announced that it will proceed with a planned increase in the consumption tax rate from 5% to 8%, effective April 1, 2014.
The tax accounting items on the new business plan cover a wide range of transactions and therefore should be of interest to many taxpayers.
Missouri bad debt deduction sales tax; New Jersey incentives; New York City commercial rent tax; deductibility of management fees
On October 11, 2013 the Chancellor announced that the UK and Isle of Man had signed an automatic tax information exchange agreement based on FATCA (the US Foreign Account Tax Compliance Act). This Newsbrief provides an update and background information on the agreement.
The sequestration rate applicable to Treasury Section 1603 grant programs will be 7.2%.
This Insight discusses the 2013 proposed regulations.
Chairman Camp has reaffirmed his commitment to plan to overhaul the US tax system in time for a markup in the fall.
China, South Korea, Thailand plan to subsidise solar power; India and the UK plan to support wind energy; and France is increasing its support for biogas power
This quarterly publication discusses critical tax legislation and regulatory developments that may impact entertainment, media and communications companies.
This newsalert summarizes those provisions in the circular that could affect foreign investors in India.
An account receivable established under Rev. Proc. 99-32 may constitute increased related-party indebtedness for purposes of the related-party debt rule
In this issue, our authors explore two different avenues that states may take to offer incentives to businesses.
Discusses in depth the recently issued final regulations regarding the deduction and capitalization of expenditures related to tangible property
Companies that have sold assets which were used to generate FSC commissions or ETI exclusions may be able to restore a portion of the basis of these assets.
Regulations on the exception from the definition of 'qualified research' for internal-use software under Section 41(d)(4)(E).
New guidance for companies beginning construction in 2013 on renewable electricity projects that qualify for the production tax credit.
Tax Court held that the amount of carried loss reserves claimed by an insurance company under Section 832 was fair and reasonable
This Newsbrief describes key changes contained in the technical correction and provides observations.
This is the first in a three-part series that will discuss the recently issued final regulations regarding the deduction and capitalization of expenditures.
Twenty one guidance projects addressing consolidated return issues or other issues relating to corporations and their shareholders.
The IRS released final tangible property 'repair' regulations regarding the deduction and capitalization of expenditures related to tangible property.
IRS announced in Notice 2013-56 that it would be providing penalty relief for incorrect name and taxpayer identification number combinations reported.
IRS concluded that the post-death beneficiary of five annuity contracts could exchange the value of those contracts tax-free for higher payouts.
Newly proposed Section 174 regulations address several long-standing issues related to the deduction for research or experimental (R&E) expenditures
The new regime applies to a wide range of companies across all industries, including industrial products and services companies.
Efforts to advance tax reform legislation move into a critical phase this fall.
On August 29, 2013, the IRS released a new Form W-9, Request for Taxpayer Identification Number and Certification and its instructions. The Form W-9 is one of several forms being revised to conform to the provisions of FATCA. This Newsbrief provides an overview and key observations of the new Form W-9.
IRS has provided domestic asset/liability percentages and domestic investment yields for foreign insurance companies.
Geosyntec Consultants, Inc. v. US, US District Court ruled that research conducted under fixed-price contracts held not 'funded,' eligible for research credit
Insights exploring unclaimed property, credits and incentives, and state income tax reporting for retailers.
On August 14, 2013, HM Treasury and HMRC issued updated Guidance Notes ("UK Guidance") in respect of the Implementation of The International Tax Compliance (United States of America) Regulations 2013 ("UK Regulations") laid before the UK House of Commons earlier this month. This version of the guidance supersedes any versions previously published. This Newsbrief identifies key changes and certain additions from the draft UK Guidance released in May 2013.
This publication discusses key tax and financial reporting considerations of patent box regimes and other technology incentives.
Deductions for policyholder dividends did not satisfy the 'all-events' test under the principles of Section 461.
The Internal Revenue Service (IRS) announced the opening of the Foreign Account Tax Compliance Act (FATCA) registration system on August 19, 2013. This Global IRW Newsbrief provides background information, important deadlines, key observations, and next steps.
Retailers may have a time sensitive opportunity to qualify for current enterprise zone benefits before the credits expire at the end of 2013
New Mexico and Virginia have enacted special state income tax rules for retailers
Key observations from HM Treasury and HMRC's release of the International Tax Compliance (United States of America) Regulations 2013 to improve international tax compliance and implement FATCA.
Understanding its impact and the path forward for nonfinancial multinational businesses.
These procedural changes are intended to make it easier for FBAR filers to use the e-filing system.
IRS directive for use in determining whether a taxpayer has the benefits and burdens test for purposes of Reg. sec. 199
Final regulations explaining the exception for certain expenditures paid or incurred under a reimbursement or other expense allowance arrangement
The IRS has released guidance (Notice 2013-51) on the procedural requirements related to the branded prescription drug fee ("the fee") for the 2014 calendar year. This annual fee, which applies to companies that manufacture or import branded prescription drugs, was enacted as part of health care legislation in 2010 and applies to each calendar year beginning after 2010. For 2014, the aggregate amount of the fee that is to be allocated proportionally to covered entities is $3.0 billion.
The IRS issued temporary and proposed regulations addressing identified mixed straddle transactions.
China and the United States both launching initiatives in recent months to reduce greenhouse gas emissions and drive sustainable growth.
General overview of elections and accounting methods
The IRS recently issued guidance regarding the deferral of gross income in connection with certain advance payments received from the sale of gift cards.
China and the Netherlands recently entered into a new double taxation agreement (DTA) and protocol.
The monograph provides an overview of developments affecting the taxation of insurance companies in 2012.
Tax code provisions offer relief to taxpayers affected by disasters.
The Obama administration decision to delay reporting and enforcement of employer mandate is welcome relief for all employers that would have been subject to the reporting requirements and shared responsibility payments. Pharmaceutical and Life Sciences companies will now have additional time to determine their coverage responsibilities and to implement the necessary recordkeeping and reporting capabilities.
OECD published an Action Plan that addresses the perceived flaws in the international tax rules that were discussed in the BEPS report
The latest edition of Continuing Developments in the Taxation of Insurance Companies from PwC reviews developments affecting the taxation of insurance companies, with a special focus on legislation, tax accounting, and Federal, international, and multi-state taxation developments.
Australia has enacted new loss carryback rules that will give Australian companies the option to carry back tax losses to a preceding tax year.
CA AB 93 and SB 90 make sweeping changes to the California Enterprise Zone credit program
The IRS recently issued a directive to all LB&I employees that should improve the way that they, and taxpayers, deal with Information Document Requests.
Additional year before the mandatory employer and insurer reporting requirements under the Affordable Care Act
CA AB 93 replaces most of the current program with a new hiring credit, a new sales and use tax exemption, and a negotiable tax credit for certain investments
PLR 201323009, the IRS granted an insurance company an extension of time to file an election to be subject to the alternative tax under Section 831(b)
Rev. Proc. 2013-32 will restrict the scope of letter rulings issued under sections 332, 351, 355, 368, and 1036
MO S.B. 287 allows for sponsored captive insurance companies and respective protected cells to be organized and operate in the state
Senate Finance Committee Chairman Max Baucus and Ranking Member Orrin Hatch issued a letter to all Senators setting forth next steps
This quarterly publication discusses critical tax legislation and regulatory developments that may impact entertainment, media and communications companies
Senate Bill 1133 was introduced to permanently extend the New Markets Tax Credit
Litigation between the IRS and Wells Fargo over access to tax accrual workpapers has been resolved by the trial court.
The IRS has recently released drafts of certain FATCA-related forms.
Understanding the effects of the European Commission's proposed amendments to the automatic exchange of information ("AEOI") between EU Member States.
The IRS concluded that a written collaboration agreement constituted a partnership for all federal income tax purposes.
This Newsbrief identifies key changes from the draft UK Regulations released in December and highlights relevant aspects of the associated Guidance Notes.
Chinese State Administration of Taxation has clarified how local-level tax bureaus should assess beneficial ownership
This Newsbrief provides an overview of the key elements of the German-U.S. IGA and how it compares to the Model 1 IGA.
Emissions trading, carbon tax, carbon markets, carbon price support, renewable energy, cleantech, subsidy, environmental policy, landfill tax, climate change
A memorandum directing LB&I staff to not challenge the treatment of certain 'eligible milestone payments' paid in the course of a covered transaction.
The Neal Bill would limit deductions for reinsurance premiums paid by a US insurance company to its foreign affiliates.
Permits taxpayers to elect to treat certain dispositions of a target corporation's stock as a sale of the underlying assets of the target corporation.
The IRS concluded that minimum royalties paid for the use of licensed patents must be capitalized to ending inventory under Section 263A.
The Australian 2013 – 2014 federal budget, released on May 14, contains a number of measures aimed at increasing Australian tax revenue.
Determining whether expenditures to maintain, replace, or improve steam or electric power generation property must be capitalized under Section 263(a).
The House Ways and Means Committee May 8 held a meeting covering the work of certain of its 11 bipartisan working groups on tax reform
The RCF case confirms that it is possible to look through an LP to identify the relevant taxpayer for purposes of applying a tax treaty.
LB&I recently issued a memorandum for all staff regarding the treatment of eligible milestone payments paid or incurred in the course of certain transactions.
JCT staff today issued a 568-page report on 'Present Law and Suggestions for Reform Submitted to the Tax Reform Working Groups'
The IRS concluded in a field attorney advice (FAA 20124401F) that minimum royalties paid for the use of licensed patents must be capitalized in part to ending inventory under Section 263A.
Pharma and Life Sciences Tax News, Vol.12, No. 6: IRS disallowance of research credit for employee separation payments validates importance of documentation - 30 April, 2013
Important guidance for entities that are classified as FFIs under FATCA and considering applying for qualified intermediary, withholding foreign partnership, or withholding foreign trust status.
A taxpayer can meet the special rule for government contracts under Section 199.
The IRS provided applicable guidance implementing both a physical work standard and providing an economic safe harbor.
A recent PLR permitted the taxpayer to claim 'bonus depreciation' by filing Form 3115, Application for Change in Accounting Method.
US District Court concluded a policyholder had basis in the shares of stock received in connection with the demutualization of five life insurance companies.
A provision that limits deductions for reinsurance premiums paid by a US insurance company to its foreign affiliates.
The IRS recently issued a memorandum for all LB&I staff that provides direction to field examiners on the repair versus capitalization issue.
President Obama's FY2014 budget proposal includes a permanent extension of the production tax credit and would make the credit refundable.
The President's budget asks Congress to "immediately begin the process of reforming the individual and business tax systems."
Form 8957, when issued in final form, may be used by foreign financial institutions (FFIs) to register for FATCA purposes.
Minimum royalties paid for the use of licensed patents must be capitalized to ending inventory under Section 263A.
Planning and development activities did not constitute a MPGE activity for purposes of the Section 199 deduction.
The UK Chancellor of the Exchequer delivered his 2013 Budget on March 20, 2013. The Chancellor reinforced the message that the United Kingdom is 'open for business'.
Payments to certain salaried employees pursuant to a 'voluntary separation program' do not constitute 'wages' eligible for the Section 41 research credit.
In this Newsbrief, we take a closer look at the potential impact of FATCA on the global captive insurance market.
To accelerate use of these credits, an election must be made under Section 168(k)(4).
Development activities held not Section 199 manufacturing activities
There could be a change to the country's thin capitalization regime.
This quarter, our authors explore the benefits, pitfalls, and opportunities of some of the the state and federal tax credits.
The Senate Budget Committee on a party-line vote approved an FY 2014 budget resolution. Senate Finance Committee announced upcoming meetings.
House Budget Committee Chairman Paul Ryan (R-WI) today released a proposed FY 2014 House budget resolution.
House Ways and Means issued a 'small business' tax reform discussion draft that features proposals affecting large and small partnerships and S corporations.
The exchange by an irrevocable trust of one life insurance policy for another qualifies as a like kind exchange.In PLR 201304003, the IRS concluded that the exchange by an irrevocable trust of one life insurance policy for another qualifies as a like kind exchange under section 1035.
The IRS issued Notice 2013-19, which clarifies deficiency reserves.
IRS released AM 2012-010, a GLAM addressing application of the end-of-the-day rule and the next-day rule of Reg. sec. 1.1502-76(b)
Treasury announced that all awards made under the Treasury 1603 cash grant program will be reduced by 8.7 percent.
Amendment that would change the evidence required to prove tax residency
The budget would defer the introduction of general anti-avoidance rules to April 1, 2015.
The Australian government recently introduced draft amendments to the Australian general antiavoidance rules.
The regulations provide guidance on the key issues that arise when options or convertible partnership interests are issued to investors.
Read this PwC tax insight on new temporary tangible property regulations for general asset account treatment of property subject to Section 168.
The excise tax for offshore medical device manufacturers in Puerto Rico has been set to 4% for taxable periods from January 1, 2013 until December 31, 2017.
The Discussion Draft proposals would most significantly impact taxpayers that execute financial transactions as part of a trading or investment strategy.
The OECD released a related 90-page report, Addressing Base Erosion and Profit Shifting.
Repayment to the DRS is due by February 14, 2013.
The taxpayer had a zero basis in the shares it received as part of a demutualization.
Yesterday, the IRS announced that a second round allocation of $150 million in tax credits will be available for advanced energy manufacturing property.
Companies with manufacturing operations in Puerto Rico (PR) are subject to an excise tax on goods or services provided to offshore-related entities under Act 154 of the Internal Revenue Code. The excise tax is imposed in lieu of the PR income tax that otherwise would apply as a result of the source rule.
Companies that meet certain requirements may elect to pay an alternative tax provided in Section 831(b)
This WNTS Insight will provide updates on important treaties and protocols between the United States and key countries in Europe, Asia, and South America.
The US Department of the Treasury and the Internal Revenue Service provided welcome relief on a number of key issues for the asset management industry.
The final regulations follow last February's release of the proposed regulations.
State assumed interest rates and applicable federal rates for the determination of reserves under Section 807(d) for insurance products.
COP18 UN climate change summit, carbon markets, carbon law, carbon price support, bilateral carbon offset, renewable energy, cleantech, environmental policy
Foreign taxpayers who paid cascading insurance excise tax evaluate filing protective refund claims
The protocol is significant since it provides for exclusive residence State taxation of interest.
Key international tax law changes that could affect US multinational corporations (MNCs).
IRS Large Business and International (LB&I) Commission issued a directive not to challenge qualified research expenditures (QREs) claimed by taxpayers in the pharmaceutical sector during Stage 1 (discovery and preclinical stage) or Stage 2 (clinical trial stage) of the pharmaceutical development process if the taxpayer provides a Certification Statement regarding those QREs.
Related to the insurance industry, these final FATCA regulations contain a number of significant differences from the proposed regulations.
500 pages of guidance in the form of final regulations to implement the provisions of the Foreign Account Tax Compliance Act (FATCA)
House Ways and Means Chairman Dave Camp released for public comment a discussion draft on reforming the tax treatment of financial products.
Final regulations were issued along with a press release on January 17, 2013
The Indian Finance Minister recently announced the government's intent to accept several of the committee's GAAR proposals.
President Obama signed the American Taxpayer Relief Act of 2012 (the Act) which freezes tax rates and retroactively reinstates certain business tax incentives that expired such as the research and development (R&D) tax credit for pharmaceutical and life sciences companies. This Alert provides guidance on accounting for the retroactive reinstatement of the R&D tax credit.
American Taxpayer Relief Act of 2012 extends the research credit for two years and resolves an issue regarding the treatment of qualified research expenditures
A new whitepaper from PwCs cross isciplined Global Information Reporting practice.
Companies now should consider whether to elect general asset account (GAA) treatment for their historic depreciable property.
Proposed regs to implement and expand the application of a voluntary IRS pilot program that permits filers to truncate taxpayer identification numbers (TINs).
The previous deadline of June 30, 2013 has been extended to June 30, 2014 for eligible officers and employees to file their 2010, 2011 and 2012 FBARs.
American Taxpayer Relief Act of 2012, retroactive extensions through 2013 of certain business and energy tax provisions that had expired.
Renewable and alternative energy provisions, including a one-year extension of the production tax credit for wind energy and a one-year extension of bonus depreciation.
The bill extends certain expired and expiring business and individual tax provisions through the end of 2013.
Mass. economic development incentive program, R&D credits, jobs incentives programs
We have prepared this report to assist management teams to identify and understand the areas most frequently commented on by the SEC.
Congress is set to recess for Christmas without a 'fiscal cliff' agreement to avoid scheduled tax increases and spending reductions
This quarterly publication focuses on critical tax legislation and regulatory developments that may impact entertainment, media and communications companies.
These modifications should make the program more appealing to employers and enhance options for employers.
The IRS published regulations amending the temporary regulations to delay the effective date.
The IRS revoked an earlier ruling allowing taxpayers to include the value of facility-specific PPAs in the depreciable basis of the project.
LB&I issued a memorandum regarding examination of section 41 research credit claims in the pharmaceutical sector.
OECD recently issued several updates and consultations relevant to transfer pricing that could have important consequences for multinational enterprises.
The IRS has postponed certain tax filing and payment deadlines for affected taxpayers located in a designated disaster area.
The Chinese Ministry of Commerce recently promulgated final regulations regarding capital contributions of equity interests.
The IRS on November 30 issued proposed regulations concerning the net investment income tax under new section 1411 of the Internal Revenue Code
Section 199 domestic manufacturing deduction does not apply to a taxpayer that repackages and labels pills that it did not manufacture
The IRS has issued loss payment patterns and discount factors (Rev. Proc. 2012-44) and salvage discount factors (Rev. Proc. 2012-45) applicable to accident year 2012.
Treasury published the second model intergovernmental agreement (IGA) (Model 2) for implementing the broad-ranging provisions of the Foreign Account Tax Compliance Act.
The government is working on guidance to address three important and long-standing topics related to the section 41 research credit.
Final regulations regarding deduction and capitalization of expenditures related to tangible property (the final repairs regulations) are expected to be released in 2013.
Eleven of the European Union (EU) member states are moving rapidly towards agreement on the introduction of a financial transaction tax
The guidance describes the conditions necessary for a withholding agent to rely on a Form W-8 that is received via fax or e-mail.
Certain smart meters are eligible for five-year depreciation.
The IRS announced that Employers may provide tax-free relief to victims of Hurricane Sandy
The department of the Treasury is working to implement the information reporting and withholding tax provisions of FATCA.
Can compromises be reached before the end of this year to avoid the 'fiscal cliff' effect of scheduled tax increases and spending reductions
This report looks at the challenges that companies across the world are facing as a result of stringent and diverse transfer pricing requirements.
IRS issued a notice extending effective dates for certain provisions of FATCA and modifying a number of key concepts
UN Committee of Experts on International Cooperation in Tax Matters (the Subcommittee) approved the current unedited version of the UN Transfer Pricing Manual
The new guidance may help employers craft reimbursement arrangements intended to meet the accountable plan requirements under section 62(c).
A government-appointed Committee has recommended that India's indirect transfer rules should not apply retroactively, but prospectively only.
11 Member States support a common 'EU-wide' financial transactions tax (FTT) in their countries via an 'enhanced cooperation' legislative procedure
US v Davenport judgment to the government with respect to the taxpayers' claims for research credits related to certain software customization
The IRS recently released guidance addressing some of the very technical issues facing employers as they implement the Affordable Care Act (ACA).
An increasing number of lawsuits are being filed by technology companies surrounding patent infringement, unfair competition, fraud, and breach of contract.
CCA 201234027 IRS addressed treatment of milestone payments for purposes of applying the 70/30 safe harbor rule for success-based fees
HMRC subsequently released Implementing the UK-US FATCA Agreement Consultation Document (Consultation Document) which addresses the implementation of the US-UK IGA.
US Court of Appeals for the Second Circuit has affirmed a Tax Court decision denying Union Carbide Corporation (UCC) a research credit under section 41
The US Department of the Treasury and UK's HM Treasury announced the signing of the first intergovernmental agreement under FATCA
Authors advance the theme of knowledge. Knowledge can prevent missed tax credit opportunities and can help your company increase its state tax credits.
Congress returns this week after its August recess and is expected to resume debate over expired and expiring business and individual tax provisions, as well as scheduled cuts in U.S. defense spending and other federal programs.
The United States Court of Appeals for the Sixth Circuit on September 7, ruling in favor of the taxpayer in In re: Quality Stores, Inc., affirmed the decision of the district court that severance payments made to former employees are not wages for FICA tax purposes and are exempt from FICA tax.
Proposed regulations bar the use of negative amounts for large taxpayers unless the taxpayer uses the simplified resale method or the proposed modified simplified production method
PwC's recent study on tax rate benchmarking for 2012 in the industrial manufacturing and automotive industries.
In Exxon Mobil v. Comm. of Internal Revenue, the Second Circuit affirmed a taxpayer-favorable decision in a case regarding interest netting on tax overpayments and underpayments.
New draft Forms W-8EXP and W-8ECI may resolve conflicts over the 'capacity' of a signer.
Differing considerations may affect taxpayer decisions on accounting method changes. The number of changes that can be made without prior IRS consent has increased dramatically.
Qianhai located in Shenzhen in Southern China, may attract multinationals in modern service industries such as finance, modern logistics, information technology, etc.
In two recent decisions (Costco and Stancorp), the Oregon Tax Court confirmed the disparate treatment of in-state and out-of-state insurance companies
Certified HMO does not qualify as an insurance company, included in a unitary group's Massachusetts combined excise tax return
ISDA released a new protocol which may provide payors with an opportunity to allocate the cost of FATCA Withholding to their counterparties, rather than treat FATCA Withholding as an 'Indemnifiable Tax' for which a payor has responsibility.
Annuity receipts may be included in an insurer's premium tax credit calculation because the legislative intent demanded their inclusion
The Australian Business Tax Working Group's recent discussion paper on ways to reduce the Australian company tax rate
Today, the Internal Revenue Service (IRS) released a preliminary draft Form W-8IMY, Certificate of Foreign Intermediary, Foreign Flow-Through Entity, or Certain U.S. Branches for United States Tax Withholding.
IRS stated that a reduction in the face amount of a life insurance contract was not an alteration under the terms of the contract
IRS explains exception to the 50% deduction limitation of section 274(n) that applies to certain expenditures paid or incurred under a reimbursement or other expense allowance
Providing roadside assistance coverage to policyholders of unrelated property and casualty insurers qualifies to be taxed as an insurance company under Section 831
Open transaction doctrine does not apply where stock basis can be reasonably allocated
The IRS issued final regulations on the tax treatment of an employer with respect to certain personal use of employer-provided aircraft.
On August 2nd, the Senate Finance Committee voted to approve the "Family and Business Tax Cut Certainty Act of 2012," which would extend certain expired and expiring individual and business tax provisions through 2013.
The House approves the Job Protection and Recession Prevention Act of 2012 (H.R. 8), which would extend for one year 2001 and 2003 tax provisions for all taxpayers
Senate Finance Committee approves Family and Business Tax Cut Certainty Act of 2012, which extend certain expired and expiring business and individual tax provisions
IRS guidance on treatment under section 367(d) of transactions involving transfers of intangible property by domestic corporation to foreign corporation in corporate reorganization
Treasury released a model intergovernmental agreement for implementing the broad-ranging provisions of the Foreign Account Tax Compliance Act (FATCA).
Senate apprroved the Middle Class Tax Cut Act of 2012 (S. 3412) that generally would extend current individual tax rates for individuals with adjusted gross income below $200,000
China issues guidance for assessing beneficial ownership status when claiming treaty benefits on passive income such as dividends, interests and royalties.
A new procedure allows certain low compliance risk US taxpayers living abroad who have failed to timely file US tax returns and Reports of Foreign Bank Accounts (FBARs) to get current by filing income tax returns going back three years and FBARs going back six years.
Roadmap of China's international taxation policies for the current five-year-plan period
Federal Circuit invalidates interest capitalization "associated property rule" when applied to temporarily withdrawn property
IRS addresses how a taxpayer may demonstrate it has satisfied requirements that treats the provision of online eligible for the section 199 domestic production activities deduction
Nigerian Federal Inland Revenue Service has announced that nonresident companies must file Nigerian income tax return
House Ways and Means Subcommittee considers dynamic macroeconomic analysis of tax reform legislation.
Notice 2014-45 sets effective date regarding future 901(m) regulations for retroactive check-the-box elections.
Notice 2014-44 provides guidance regarding the application of the so called disposition rule under Section 901(m).
Under the Affordable Care Act (ACA), health plans and insurance issuers must pay a fee for seven years for plan years ending on and after October, 2012.
CBP circulated proposed revisions to its ICP on Bona Fide Sales and Sales for Exportation to the United States.
IRS directive addressing hedges of variable annuity guarantees.
Under ACA, health plans and insurance issuers must pay PCORI fees annually by July 31. The fee is paid on IRS Form 720.
These new changes are expected to significantly affect US multinational corporations.
The discussion below summarizes briefly the temporary regulations' modifications, which the final regulations preserve.
Senate Finance Committee focuses on corporate inversions and the need for tax reform.
The DTT provides exemptions or reduced rates of income tax withholding .
The IRS has issued final regulations on the Section 174 deduction for R&E expenditures.
In Wells Fargo, the Court of Federal Claims held that interest on tax underpayments and overpayments could be netted.
The Calif. Board of Equalization has granted Pacific Coast Building Products a Calif. tax refund for research credits.
Final regulations prohibit taxpayers from using identified mixed straddles to recognize built-in capital gains.
IRS guidance addresses treatment of disallowed losses associated with certain S corporation distributions.
The Directive aims to exempt from withholding taxes profit distributions paid by subsidiaries to their parent companies.
Affordable Care Act has implications for global companies doing business in the US.
Supreme Court rules a closely-held corporation does not have to provide contraceptives if it violates owners' religion.
Luxembourg guidance on use of non-Euro functional currency for tax purposes.
Court holds that base-period costs for projects similar to those without QREs should be excluded from research credit.
House approves permanent extension of bonus depreciation.
The Finance Minister of India presented Indian Budget 2014 on July 10, 2014.
Potential impact of new revenue accounting rules on incentive compensation plans and how employers can begin to prepare.
A taxpayer-favorable ruling on the deductibility of payments to parties resident in a tax haven.
House and Senate tax committees approve separate highway funding bills.
The Spanish government has released a number of bills that significantly amend the laws regarding major Spanish taxes.
VAT News highlights: CJEU addresses 'own goods' movement within EU, European Parliament supports standard VAT return, South Africa digital imports regime postponed.
Our March issue addresses key M&A proposals in President Obama's FY2015 budget and Chairman Camp's tax reform discussion draft
New legislative developments, IRS guidance, and court rulings shed light on tax accounting method issues
This issue addresses recent tax and legal changes in Philippines, Poland, & United States
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders. In this issue of HR Innovation, we focus on the continually changing HR landscape and what organizations need to do to take control of today's opportunities and tomorrow's decisions.
This issue addresses recent tax and legal changes in Australia, Greece, Hungary, Italy and Japan.
Discusses the new SIFL rates for the first half of calendar year 2014; the ramifications of executive travel to tax home utilizing employer-provided aircraft.
VAT News highlilghts: CJEU addresses incorrect VAT charges, EC cross border VAT ruling pilot project, Netherlands e-filing reminder, and digital imports in South Africa.
Provides recent news pertinent to the mergers & acquisition tax that include the latest Treasury regulations, IRS Revenue Procedures, and court decisions.
This month's AMS highlights guidance for helping taxpayers implement the final tangible property repair regulations, as well as other helpful guidance for taxpayers.
In this release we discuss a variety of global accounting, reporting and tax law developments and the related tax accounting considerations.
Explore mandatory tax reporting rules, EU rules for banking, extractive and logging industries, plus US implementation & country-by-country reporting issues.
In the current economic environment, the priority for governments worldwide – and Western governments in particular – is for their tax systems to generate the level of revenues they expect. This focus is reflected in a strong public sentiment that everyone should 'pay their fair share'. Inevitably, 'everyone' is often defined in popular parlance as large corporations. And asked whether corporations are paying their fair share of tax, growing numbers of people appear to believe – rightly or wrongly – that the answer is "no".
PwC US Tax Leader, Mark Mendola recently spoke with Tax Analysts contributing editor Jeremiah Coder on tax uncertainty, accounting firm services, and future tax policy.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders. In this issue of HR Innovation, we focus on Total Rewards, and delve into the challenges employers face of getting their employees' "total rewards" packages right.
Over 1,300 CEOs talked to us about their global talent management issues. The results of these conversations are reflected in this report.
In this release we discuss a variety of accounting and reporting developments and the related tax accounting considerations.
TP to Go is a new mobile application from the PwC global transfer pricing network that brings the best thought leadership from the network directly to your current smart phone. TP to Go is free to download on iOS, Android, and BlackBerry.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders. In this issue of HR Innovation, we focus on Healthcare for Employers, and bring to light where the opportunities and obstacles might lie post-health reform and where different paths might lead.
This publication is focused on the topics we believe will be most relevant to the preparation of 2012 year-end financial statements.
In this special edition of PwC's Perspectives, Anthony Curtis and Ogniana Todorova from PwC US take a detailed look at transfer pricing in Africa.
In this release, we discuss decisions of the International Financial Reporting Interpretations Committee along with other accounting and reporting developments.
On November 8, a group of PwC Global Structuring Partners facilitated an engaging discussion with a group of senior tax professionals on a range of issues impacting the way multinational corporations align global structures to manage their US tax burden.
Learn how and why BRIC countries have made strides as manufacturing and services countries and are now developing into significant end markets for multinationals.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders.
Corporate income tax paid by companies is an important element of the Total Tax Contribution made by companies. Calculating these taxes is often complex, varies from country to country, applies a variety of statutory rates and the rate of tax paid is usually different from those statutory rates. Understanding more fully the impact of corporate income taxes and comparing the systems implemented around the world on a like for like basis is therefore important for governments, business, and the public at large.
PwC and the National Association of Stock Plan Professionals (NASPP) are pleased to announce the release of the 2012 Global Equity Incentives Survey (GEIS): "Back to the Basics"— Executive Summary. Our survey is one of the most comprehensive studies available on the design and administration of equity incentive compensation plans for multinational companies.
Our Tax policy Perspectives series provides insight into specific topics influencing global tax policy developments, including in-depth analysis of trends in specific jurisdiction. Drawing on case law, practical experience, and knowledge of tax systems worldwide, we'll provide a global perspective on each subject area, look at how it is currently playing out in a few contrasting territories and suggest the pivotal challenges to come.
Our tax policy trends publication provides analysis and insight into the key global trends influencing the development of tax policy worldwide.
Trends in multinational businesses, unremitted foreign earnings, and recent regulatory trends
This newsletter discusses a recent update to the financial accounting convergence projects and other accounting and reporting developments along with the related tax accounting considerations.
PwC's M&A Asian Tax Guide summarises jurisdictions of the Asia Pacific area and highlights key tax issues relevant to purchasers and sellers of the mergers and acquisition transaction.
This report provides messages for companies with existing Swiss HQs which are seeking to expand their scope, assure their sustainability or reduce costs, for companies planning to implement a centralised business model but also for the Swiss authorities.
In this release, we discuss some recent updates to the financial accounting convergence projects and other tax accounting developments along with the related tax accounting considerations.
Goodwill impairment testing continues to be a challenging and complex area of practice. As companies perform goodwill assessments, tax considerations can play a critical role in the final conclusions.
This PwC reference guide helps you manage your financial services transfer pricing issues.
Key areas of focus when accounting for income taxes during interim periods
Accounting for income taxes 2011 year-end hot topics
As part of their current workplan, the SEC is analyzing the impact of IFRS on US issuers and whether, when, and how to incorporate IFRS into the US financial reporting system.
This issue of HR Innovation looks at current trends and their implications for meeting organizational goals while cultivating and sustaining an efficient, high-performing workforce in a dynamic organizational culture.
The impact of transfer pricing in financial reporting
2011 Global Equity Incentives Survey: The Rise of Performance-based Equity
Information on corporate and individual tax rates and rules in over 150 countries worldwide.


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Hi. I am a complete beginner and have no clue about cameras apart from my trusted compact one. The thing is I am opening an interior shop online and also creating a blog linking to the shop. In the blog I will post pictures of interiors(close up and whole rooms) and homes I visit. I need the pictures to come out great. I follow a few blogs myself and if the pictures are not up to scratch, then I am not interested.
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text:
FRESH @ The Steam Engine, Waterloo
Property Information:
You can see from our photos and previous guest reviews and comments that we are a highly rated, guest focused backpackers hostel that provides quality, clean and secure accommodation combined with award winning guest services so you can rest assured when staying with us.
Value for Money Services and Facilities Include:
FREE Use of In room Security Lockers (Bring your own padlock)
FREE- Daily Continental Breakfast, Served 7am 9am
FREE WiFi
FREE- Luggage Storage, prior to Check In time or after Check out time
FREE - Bed Linens, Fluffy Duvet and Pillow (Bring your own towel)
FREE London Walking Tour
FREE- Half Price Drink Voucher on Check In
7.95 Pizza Available 24 hours a day
Hair Dryer and Straightener (For a Fee)
Laundry Facilities, Washing Machine and Dryer (For a Fee)
Adaptors (For a Fee)
24 Hour Security and Reception
24 Hour Bar- You can meet people from all over the world in our bar downstairs which has three event nights weekly and offers great happy hour specials.
We also screen live sporting events from around the world on our big screens including NHL, NBA, AFL, NRL, NFL, CFL, Cricket, Olympics, Formula 1, World Rally Championships, English Premier League etc.
If you arrive early we can store your baggage free of charge in our luggage storage until check in time also when you check out you can leave your bags in our luggage storage for free until you are ready to leave.
Minimum age to stay is 18 - there are no exceptions, even if accompanied by a person aged 18 or above within the same reservation. A valid photo ID (only passports, EU Driver's licences, and EU or EEA ID Cards are accepted) is required from all guests and regardless of nationality - otherwise we are not able to check you in and you will still be charged for the amount equal to your first night's stay. By proceeding with your reservation you confirm that you accept our terms and conditions
We offer a selection of mixed dorm rooms in 9 or 12 bed configurations, which offer you the opportunity to mix with other travellers.
Our rooms are cleaned daily, with a FREE In room security locker for each guest to use. (Bring your own lock)
There are shared bathroom, toilet and shower facilities on each floor which are kept clean and tidy by our dedicated staff to ensure they are fresh 24/7.
The hostel is only a 10 minute walk from the London Eye and we are so close to Lambeth North underground station you can be in Piccadilly Circus in only 15 minutes. We provide free London walking tours.
Please note that check-in time is after 2pm. You must be over 18 to stay at our hostel and a valid ID is required when you check-in.
Availability & RatesTo view availability and prices please select dates and click 'Update Dates'
Hostel Facilities & Policies
- 24 hour reception
- 24 hour security
- Adaptors
- Age Restriction
- Bar
- Bicycle parking
- Breakfast Included
- Cable TV
- Credit Cards Accepted
- Free City Maps
- Free Wifi
- Hot Showers
- Linen Included
- Lockers
- Luggage Storage
- Non Smoking
- Taxes included
- Tea/Coffee Making Facilities
Cancellation PolicyThis property has a 2 day cancellation policy. Failure to cancel within this time will result in a cancellation charge equal to the first night of your stay.
Must-Read Hostel InfoThis property has specific Terms & Conditions.
AGE POLICY: We do NOT accept ANY Guests aged under 18 years old- minimum check in age is 18 years
old. A person under 18 cannot be checked in even if accompanied by an adult. Underage arrivals
will be processed as a NO SHOW (First night charged, and remainder of booking cancelled)
ID POLICY: You must present Valid Government Issued Photo ID we ONLY accept: Passport, EU-Issued ID
Card, EEA/EFTA Issued ID Card (such as Switzerland, Norway, Iceland, and Liechtenstein), and
EU-Photo Driver's License. No copies are accepted, paper or electronic. A Student card or
a bank card is not accepted as an ID. NO ID, NO STAY, NO EXCEPTIONS
NO SHOW POLICY: If you do not arrive for your booking by 6am the morning following your scheduled date of arrival
we consider that a 'NO SHOW' and reserve the right to charge your credit card the total for your first night's stay and
cancel the remainder of your booked nights.
Check In: From 2pm
Check Out: 10.30am
DirectionsShow MapHide Map
Address: The Steam Engine, 41-42 Cosser Street, London, SE1 7BU
Please consult the official Transport for London travel planner www.tfl.go.uk for step by step directions to the hostel at the time of your travel.
We are located in Zone 1, on Cosser Street a short walk (3 minutes) from Lambeth North Tube Station on the Bakerloo Line.
Notable tourist attractions within walking distance are Big Ben, Westminster Abbey, London Eye, Downing Street, Houses of Parliament, Trafalgar Square and Waterloo Station.
From Lambeth North Underground to The Steam Engine:
From Lambeth North Station, when you exit the station you will see a large Church, cross the road and walk past it so that it is on your left, you are now on Kennington Rd. Walk about 200 meters and you will see Cosser Street on your right (just behind Days Inn Hotel) (if you get to a set of traffic lights you have gone to far), we are 20 meters down this road on the left.
From Waterloo to Lambeth North Underground
Take the Bakerloo line towards Elephant and Castle to Lambeth North
Located Near
5 min walk or 1 tube stop and you are at London Waterloo Station (Rail, Underground & Bus Services)
15 min walk or a short bus ride to London Bridge, London Tower (show case of the Crown Jewels), and London Walking Bridge
15 min walk or very short bus ride the other way to Westminster Abbey, Parliament, Big Ben, and Buckingham Palace and of course the London Eye which you can see from the pub.
Easy tube or bus ride into SOHO night life, shopping, and all that downtown has to offer.


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HOME Sanuk Gear Sanuk Ladies Sanuk Ladies Footwear Sanuk Ladies Footwear Sandals (60 items) Product ID: 383056
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Make a splash while finding your center in these Yoga Rain Dance sandals from Sanuk featuring a footbed made out of a real yoga mat!
- Imported
- Sanuk footbed made from real yoga mat
- Sanuk screen print on footbed
- Sanuk signature Happy U embossed outsole
- Self-binding liner
- T-Straps featuring synthetic cracked leather and multi-color stitch
- Vegan and vegetarian
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Special event items are produced by manufacturers only after the outcome of a game or event. These are advanced sale items and will ship immediately after they are received in our warehouse.
Manufacturer direct items are shipped directly from the manufacturer. These items are not available for international or expedited shipping.
Customized items can be personalized with options such as your name, your favorite number, and/or designs. Some options may be limited by league rules.


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Ostheimer Lamb, Resting
This sweet resting Lamb from Ostheimer will be a peaceful addition to your child's family of wooden farmyard animals!
1¾ inches high
Ages 3 and up
Ostheimer wooden toys are handcrafted from select European hardwoods.
Made in Germany
Ostheimer wooden figures are hand-crafted and painted with plant-based watercolors that are non-toxic and child-safe.
All Ostheimer toys meet or exceed strict EU safety testing standards.
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Copyright 2002-2014, Bella Luna Toys.


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All of my readers will get the chance to design a dress especially for me, with the possibility of it being sold in the Fashiolista pop-up sale! How cool is that?
To enter simply:
1. Register on Fashiolista here if you haven't already
2. Design a dress for me at United Styles
3. Add your design to Fashiolista by clicking the "heart." Make sure to tag the dress with 'United Styles' and 'Dress Design for Natalie Off Duty' to be entered!
- Now collect as many loves for your design on Fashiolista as possible, by sharing it with your friends, followers and other style lovers! Get creative!
To see all the entries, go to the official contest page!
Good luck everyone! Can't wait to see what you guys come up with!


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The Top 10 In Action Sports
01Champagne, Cabaret And Raving With The Pope: We Meet The Man Behind The Craziest Après Bar In The Alps...
02France Vs. Austria: Which is Better for Skiing & Snowboarding?
03WARNING: These Incredible Photos of #VanLife Will Make You Want to Jack In Your Job
04Bad-Mouthing, Board Stabbing and Full On Fist Fights in the Water: These Are the Greatest Rivalries Surfing Has Ever Seen
0510 Terrifying Pistes Every True Skiier Needs To Ride Before They Die
06No Waves? No Problem. This Guy Can Turn Any Beach Into A Surfing Nirvana. He Just Needs £50,000...
07This Documentary About Illegal Longboard Racing in Hawaii is Strangely Compelling...
08She Was Attacked By A Stranger Outside Her House, Now Steph Gilmore Has Conquered Her Fears But Will She Claim Her Sixth World Title?
09This Company Will Turn You Into Snow After You Die... And Then Let You Fall On The Mountains
10Facebook Isn't Just For Stalking And Selfies: Now It Could Save Your Life...
Flips second 'Industry' section (1998)
A Skateboarding video by Sidewalk - 27,161 views
The Flip 'Industry' section from 411 30 (1998), featuring rare footage of Eric Brockman, Alex Moul and Ali Boulala.
What Do You Think?
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Gundlach Bundschu Winery is a family-owned, sixth-generation producer of distinctive wines of site-specific character. The winery's 320-acre Estate Vineyard, christened Rhinefarm in 1858, is located at the crossroads of the Sonoma Valley, Carneros and Napa Valley AVAs, at the base of the Mayacamas Mountain Range.
Gundlach Bundschu approaches its vineyards, wines, business and...Read More About Gundlach Bundschu
Twice as large as Napa in size, Sonoma County only makes about a half the amount of wine as her northeasterly neighbor. But Sonoma, with her size, is able to vouch for more diversity within her borders, including sub-AVAs that are climatically varied. The atmosphere of Sonoma is decidedly laid back and down home country style. But in wines, they are keeping up with the...Read More About Sonoma County
(cab-uhr-NAY sow-veeh-yawn) King of Red Many refer to Cabernet Sauvignon as the king of red grapes. Perhaps that title is due to its ability to grow worldwide in a number of climates, or to the fact that it produces wine with such character yet such diversity. Either way, this grape is responsible, as a whole or a partner, for some of the greatest wines in the world. In Bordeaux,...Read More About Cabernet Sauvignon
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Coldwell Banker Hedges Realty- View Local Website
5408 Blairs Forest Way NE Cedar Rapids, IA - View on map
Phone: (319) 378-8760
Fax: (319) 378-8767
Interested in a career in Real Estate? Work with a Real Estate company that works for you. Learn more about Careers with us, or
Contact Coldwell Banker Hedges Realty
Office: Coldwell Banker Hedges Realty Address: 5408 Blairs Forest Way NE, Cedar Rapids, IA 52402 Office Phone: (319) 378-8760 Business: (319) 378-8760 Fax: (319) 378-8767 Email: firstname.lastname@example.com
About Coldwell Banker Hedges RealtyColdwell Banker Hedges is the premier real estate company in the Cedar Rapids, Marion, and Hiawatha area with two offices. Cedar Rapids - Iowa`s second largest city - is eastern Iowa`s leader in business and industry.
- English
- German
- Spanish
Specialty Markets
- New Homes
- Farm & Ranch
- Homebuyer Ready
- Luxury Properties
Office Specialties
- Over 100 full-time agents.
- Committed to serving our clients with respect!
- Arrange a worry-free move.


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$6.99 Flat Rate Shipping. Any Size Order!
Orlando Magic Online Store
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Show off the pride and passion of being a fan for the team that turned Howard into Mr. Double Double with this tee from ESPN. Featuring team-colored stacked lettering and custom talk bubble graphics, this tee packs enough team spirit to keep any Magic ready for action all season long!
- 100% Cotton fabric
- Imported
- Lightweight ribbed T-shirt
- Officially licensed NBA product
- Rib-knit collar
- Screen print graphics
- Tagless collar
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Special event items are produced by manufacturers only after the outcome of a game or event. These are advanced sale items and will ship immediately after they are received in our warehouse.
Manufacturer direct items are shipped directly from the manufacturer. These items are not available for international or expedited shipping.
Customized items can be personalized with options such as your name, your favorite number, and/or designs. Some options may be limited by league rules.


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Free forum : A review of all rep bags from Jacky, Fang, Joy, Shaly, NBF, Catty and from sellers on Ioffer. A forum where everyone could share ideas on rep bags.
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An RP forum for mature RPers willing to relax and have fun. A refuge for a friendly community. Specialized in anime-style Roleplays, though we try to experiment iwth new ideas.
newts, suits, roleplays, forum, mature, rpers, willing, relax, have, refuge, friendly, community, specialized, anime-style, though, experiment, iwth, #ideas
A fansite forum once dedicated strictly to Cartoon Network's biggest game ever, FusionFall, we have now branched out to various other games such as DC Universe, Wizard 101, Eden Eternal, Consoles and more!
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A place to share thoughts and ideas about publishing and marketing books.
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Friends sharing recipes, cooking techniques & menu ideas in a friendly atmosphere.
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Free forum : I am building a place for mums to come and hang out with other mums, share stories, craft ideas, art, recipes, trends, whatever us mums do we can share it here!
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A unique blend of Original and Inspired Ideas all formed into one RP.
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Free forum : An RP forum built upon the combination of Gundam canon as shown in 'Gundam Dynasty Warrior 3/Gundam Musou 3'. Open to original ideas and content.
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Biker-Haven is a refuge for a true brotherhood of bikers that ride all brands of motorcycles, to come and exchange ideas, talk tech, visit with old friends, make new friends, share experi
We are a group of like-minded people who come together to share ideas and encourage each other ... oh ... and we also enjoy the occasional swap as well ...
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Free public forum for advanced and productive discussion of philosophy and related subjects
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swap ideas, brag about your victories, and post your suggestions for the clan here!
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Quilling forum: Welcome to our friendly forum for Quillers to share ideas and creations with one another. Whether you have been quilling for a short time or an eon, we value your input.
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Free forum : What is SWW? SWW is a forum where people looking to meet others, make new friends, dating, networking, sharing ideas, postings, post replies, comments & much more.
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Discussion boards for community members of Classical Conversations Tampa Central to share ideas, information and support.
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Below is our list of services offered by this office.
Steve "Mac" MacLellan is the President of the Central Region for Northern Trust's Wealth Management business. In this capacity he is responsible for leading the region's investment management, banking and fiduciary business for Northern Trust's offices in Illinois, Ohio, Michigan, Minnesota, Wisconsin and Missouri. In addition, MacLellan is a member of the Northern Trust Operating Group, the Northern Trust Wealth Management Executive Committee and is a board member of Northern Trust Securities Inc.
Prior to his current role, MacLellan was the Global Head of Business Practices and Client Segments for Northern Trust's Wealth Management business. In that capacity, he oversaw Wealth Management's professional business practices (investment management, private banking, personal trust and advisory services) as well as Wealth Management's core client segments (Wealth Advisory, Private Client Services, and Foundations & Institutional Services). He was also responsible for the business unit's sales and marketing functions. Prior to assuming this role, MacLellan served as President for Northern Trust's Wealth Management business in the Southwest Region (Arizona, Texas and Colorado). And prior to that assignment he served as National Director of Wealth Advisory Services.
Daniel J. Pienta is Senior Vice President and Managing Director of Northern Trust in Bloomfield Hills, Michigan. In this capacity he manages the Trust, Investment Services and Private Banking groups within the financial center. Dan also serves as the Chief Banking Officer for the state of Michigan. He has over twenty five years experience in a broad scope of financial services disciplines.
Dan joined Northern Trust in June of 1999 after nineteen years with the former NBD Bancorp and its' successor organizations. During that tenure he had a variety of responsibilities that included Commercial Banking, Corporate Cash Management and Retail Banking.
Dan holds a Bachelors of Arts degree in Economics from the University of Michigan and has participated in a variety of banking related training and development programs. He holds Series 7, 66 and 24 registrations with the NASD. Dan is a member of the Board of Trustees for New Horizons Rehabilitation Services, Inc. and has previously served on the Finance Committee at the Detroit Athletic Club.


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Renault have warned late-paying teams that they are risking their own performances if the money isn't there for development.
The French engine manufacturer, who supply Red Bull, Lotus, Toro Rosso and Caterham, revealed in Spain that some teams were late in paying.
And at a time when Renault need the finances to recover from their early-season woes, Renault Sport F1 head Jean-Michel Jalinier has warned the teams risk their own form.
"In order to develop the action plan we need to secure resources and our resources are coming from two sources," Jalinier said.
"One is Renault, and we have been able to secure the right resources, even human resources or financial resources, and the other part of it is coming from the teams because we are selling the engines to the teams.
"On this part I must say we are not at an acceptable situation, because some of the teams are just late in payments, and at the time you need to spend resources to catch up you cannot afford to have those [late] payments."
Jalinier, however, refused to name which team or teams were late.
Any reproduction, publication or redistribution of this material without the written agreement of 365 Media Group is strictly forbidden.


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Red wines that are more fruit-forward and lighter in tannin and body.
Medium bodied reds that go down easy, with smooth tannins and supple fruit.
Wines where earthy and/or spicy dominate the flavors – typically medium to full body.
Full bodied wines that have concentrated fruit and are higher in alcohol and/or tannins. Some need age.
Our Mirassou California Pinot Noir displays fresh fruit flavors of pomegranates, cherries and currants with complementing aromas of strawberries, pomegranates and cherries. This wine is at its best if enjoyed within a year of release, but can age in the bottle for up to three years if carefully cellared.
Since 1854 the Mirassou family has dedicated itself to mastering the art of winemaking. 150 years later, their passion and optimism are stronger than ever. In 2004 the 6th generation of this winemaking family celebrated the launch of a new line of crisp, fruit-focused wines honoring their 150th anniversary as a California winery.
California has nearly 100 American Viticulture Areas (AVAs) and accounts for almost 90% of wine production in the United States. In our section of Other California, we include wines from smaller AVAs as well as wines from the California AVA. Here are a few smaller AVAs you may see on the label:
Livermore Valley AVA, located right outside of San Francisco and home to...Read More About Other California
Pinot Noir(PEE-noh nwahr)
Pinot Noir is a finicky grape. It only grows in
the right climate, with the right soils and the right care. Perhaps because
it is so difficult is why it is so loved. Pinot Noir hails from Burgundy, a region known for crafting the most collectible and sought-after wines from this varietal.
Not only does Pinot reign in Burgundy, it is also...Read More About Pinot Noir
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