SALT & Pepper

  • Taxing and Legitimizing the Sharing Economy

    The so-called “sharing economy” has recently gained a lot of steam. This model, which helps owners of nascent high value assets pair up with possible users of those assets, has been cited among the most dynamic and exciting types of start-ups over the past few years. In fact, just this Monday, Illinois Governor Pat Quinn vetoed legislation that would have seriously restricted the extent to which the ride sharing app Uber may do business in the state, citing a fear of stifling innovation. As is often the case, however, the dynamism of these new business models appears to be clashing with the archaic regulations and taxes which might govern the industries upon which these “sharing” businesses are encroaching.
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  • Piercing the Corporate Veil in Canada When Company Is Used to Misappropriate Funds

    Fraudsters cannot hide behind a corporate shield in Canada when they use a company for an “illegal, fraudulent or improper purpose.” The Ontario Court of Appeals in Shoppers Drug Mart Inc. v. 6470360 Canada, Inc., 2014 ONCA 85, addressed the situation where Shoppers Drug Mart (“Shoppers”) contracted with the defendant Energyshop Consulting to manage and pay utility bills for Shoppers’ stores nationwide...
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  • Michigan IBM Decision May Provide More Opportunities Than the 3-Factor Election

    On July 14, 2014, the Michigan Supreme Court ruled in IBM v. Department of Treasury, Docket No. 146440, that the taxpayer, IBM, was entitled to a refund of income taxes paid to the state by virtue of its election to apportion its income using the three factor apportionment formula provided in the Multistate Tax Compact, MCL 205.581 et seq. The opinion has garnered a lot of attention, as it is the first state supreme court decision addressing whether taxpayers should be permitted to elect the three factor formula in MTC states. However, the case did very little to assure taxpayers that a multistate compact is in fact binding on its state members. Instead, the case turned on statutory interpretation and a provision in the Business Tax Act that provided that a taxpayer could not utilize the three factor formula beginning January 1, 2011.
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About HMB Law

Welcome to HMB's SALT & Pepper blog. As the title suggests, this blog tracks important and emerging issues, trends and developments that affect our clients not only in State and Local Tax (SALT) but also in other disciplines and industries. This blog is designed to be a helpful resource. We hope our readers will find it practical, insightful and valuable.

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