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Morgan Lewis

Federal Fiscal Court Issues Two Rulings on the Requirements for a Consolidated Tax Group for Income Tax Purposes - Legal Insights...

Morgan Lewis on

In two rulings, the Federal Fiscal Court (BFH) ruled in favor of the taxpayer on the requirements for a consolidated tax group for income tax purposes. Managing holding partnership as controlling company (judgment of November...more

Proskauer - Tax Talks

BlueCrest – the Court of Appeal considers Condition B of the salaried members rules

Proskauer - Tax Talks on

The Court of Appeal has remitted the case of BlueCrest Capital Management (UK) LLP (BlueCrest) v HMRC back to the First-tier Tribunal (FTT) regarding the application of the UK’s salaried members rules (the Rules) to certain...more

DarrowEverett LLP

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

DarrowEverett LLP on

In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

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