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Statutory Interpretation Taxation Income Taxes

Cadwalader, Wickersham & Taft LLP

Beard v HMRC: Capital Dividends. A Triumph of Form Over Substance?

Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more

Rivkin Radler LLP

Taxes: An American Obsession?

Rivkin Radler LLP on

Last week the United States celebrated the 249th anniversary of its declaration of independence from Great Britain. In celebration of the occasion, President Trump signed into law the One Big Beautiful Act which, among other...more

Bilzin Sumberg

Playing Battleship with the IRS: Did They Sink Our Battleship?

Bilzin Sumberg on

In prior posts, I discussed the dangers of playingBattleship with the IRS and how taxpayers scored “a hit”.  Recently, taxpayers took another turn in the game and scored another hit with the District Court’s recently issued...more

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