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Littler

Recent U.S. Tax Court Opinion Illustrates How Language in Settlement Agreements Can Determine Tax Treatment of Payments

Littler on

In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more

Miller Canfield

Are Wages for Research Credit Purposes Limited to “Reasonableness?”

Miller Canfield on

Smith v. Commissioner, a pending research credit case in the United States Tax Court, presents an issue of first impression: Is a partner’s self-employment income in a partnership allowable as a qualified research expense...more

Stikeman Elliott LLP

Tax Court of Canada Denies GST/HST Input Tax Credit Claims in Connection with a Settlement Payment

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In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...more

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