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Tax Deductions › Tax Appeals › Tax Court

Morgan Lewis

Düsseldorf Fiscal Court: Legal and Consulting Fees for Sale of Second-Tier Subsidiary Fully Deductible Irrespective of an Existing...

Morgan Lewis on

In its decision dated February 26, 2025 (7 K 1811/21 K), the Düsseldorf Fiscal Court concluded that legal and consulting fees incurred by the indirect sale of a second-tier subsidiary by the subsidiary are deductible business...more

Cadwalader, Wickersham & Taft LLP

Complex Borrowing and Group Structures

Cadwalader, Wickersham & Taft LLP on

The Court of Appeal’s (“CA”) ruling in April 2024 in the case of BlackRock Holdco 5 LLC v HMRC (“BlackRock”) considered the deductibility of interest on a $4 billion intra-group loan put in place as part of the funding...more

McDermott Will & Schulte

Microsoft Scores Massive Win in California, Opens the Door for Others Nationwide

McDermott Will & Schulte on

The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more

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