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Tax Liability Sovereign Immunity

Ballard Spahr LLP

Supreme Court: No Strong-Arming the Federal Government With State-Law Fraudulent Transfer Claims

Ballard Spahr LLP on

Recently, in the case United States v. Miller, the U.S. Supreme Court held that the sovereign immunity waiver provision in the Bankruptcy Code is jurisdictional only and does not waive the federal government’s sovereign...more

Goodwin

UK Consultation on Sovereign Immunity from UK Direct Tax - Implications for Real Estate Investments

Goodwin on

​​​​​​​HM Treasury and HM Revenue and Customs (HMRC) are consulting on proposed changes to the U.K.’s existing approach to sovereign immunity from U.K. direct taxation. The proposed changes would be a major step change in the...more

Cadwalader, Wickersham & Taft LLP

UK Government Considers Changes to the Rules on Sovereign Immunity from Direct Taxation

The UK Government has recently consulted on a revised approach to sovereign immunity from direct taxation. The consultation was brought about owing to the view that whilst the scope of sovereign immunity-based exemptions has...more

BCLP

Sovereign investors likely to start paying UK tax - impact on UK real estate investment

BCLP on

The UK government is consulting on bringing overseas sovereign investors in UK real estate within the scope of UK direct tax from April 2024 as part of measures amending the scope of the sovereign immunity tax exemption. ...more

Freeman Law

IRS Summonses and the Collection of Unpaid Taxes

Freeman Law on

This post focuses on the recent case of Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7, 2022). The recent Sixth Circuit’s recent opinion in Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7,...more

Freeman Law

Missed Window—Taxpayer Loses Chance to Sue IRS on Claim for Refund

Freeman Law on

In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have...more

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