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Eversheds Sutherland (US) LLP

Eversheds Sutherland SALT Scoreboard – Quarter 1, 2025

Eversheds Sutherland (US) LLP on

This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more

Holland & Knight LLP

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

Holland & Knight LLP on

In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

Eversheds Sutherland (US) LLP

Legal Alert: New York Tax Appeals Tribunal Reverses “Distorted” Knowledge Learning Decision and Provides Guidance for Proving...

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On September 18, 2014, the New York State Tax Appeals Tribunal (Tribunal) decided its first combination case addressing the 2007 changes to New York’s combined reporting regime: Matter of Knowledge Learning Corporation and...more

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