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Morgan Lewis

Federal Fiscal Court on Trade Tax for Commercially Infected Upper-Tier Partnerships - Legal Insights Germany

Morgan Lewis on

The German Federal Fiscal Court (BFH) confirmed its case law according to which the commercial infection of an upper-tier partnership pursuant to Section 15 para. 3 no. 1 sentence 1 alt. 2 German Income Tax Code...more

Akerman LLP - SALT Insights

It’s None of My Business! Arkansas Court Rules on Business v. Non-Business Income Distinction

Akerman LLP - SALT Insights on

Income received by a multistate business is either “business income” or “non-business income.” Although this labeling appears innocuous, the distinction between these two categories of income matters greatly to taxpayers and...more

Rivkin Radler LLP

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

Rivkin Radler LLP on

Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

Bennett Jones LLP

Tax Court Affirms Treaty-Based Canadian Holding Structure

Bennett Jones LLP on

The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance rule ("GAAR") did not...more

Eversheds Sutherland (US) LLP

Tax Court Rejects IRS’ Position in Rev. Rul. 91-32

Eversheds Sutherland (US) LLP on

Grecian Magnesite Mining, a Greek corporation (GMM), owned an interest in Premier Chemicals LLC, a Delaware limited liability company classified as a partnership for US income tax purposes (Premier). Premier conducted a trade...more

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