Impuesto de Timbre: Cuantía indeterminada
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
Exploring Carried Interest in Upper Tier Private Equity Structures — PE Pathways
Insider Transaction Traps for the Unwary
Essentials for Balancing Taxes and Legal Risk
Business Better Podcast Episode: Bridging Campuses: Legal Insights on Education Industry Consolidation - Real Estate and Tax
Maximizing Financial Growth: Insights on HSAs and Smart Investment Strategies with Shaun Eddy
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
5 Key Takeaways | Income Tax Jeopardy! A Potpourri of Hot Topics
REFRESH: Loot and Private Foundation Rules – Part 2
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Candidate Campaign Intervention
Domestic Tax Planning - Podcast with Janathan Allen
Tax Liability Insurance Products: A Hidden Gem in the Transactional Lawyer’s Tool Box
JONES DAY PRESENTS®: Tax Implications of Telehealth as Remote Services Become Norm
Podcast: Got Mail? What to Do When the IRS Contacts You [More with McGlinchey, Ep. 42]
The Tax Court recently ruled for the IRS in another case involving the “limited partner exception” under the Self Employment Contributions Act (SECA). Code Section 1402(a)(13) generally exempts the distributive share of...more
On June 12, 2025, the U.S. Supreme Court issued a significant decision in Commissioner of Internal Revenue v. Zuch, clarifying the jurisdictional boundaries of the U.S. Tax Court in Collection Due Process (CDP) appeals....more
In a pivotal ruling, the U.S. Supreme Court on June 12, 2025, held that the U.S. Tax Court lacks jurisdiction to hear a taxpayer’s Collection Due Process appeal under IRC § 6330 once the IRS can no longer pursue a levy,...more
The Ohio Supreme Court issued a decision on June 18 that Ohio Commercial Activity Tax (CAT) taxpayers should consult for insights that may strengthen their ability to claim the exclusion from the CAT for money or revenue...more
The recent federal district court decision in Faulk Company, Inc. v. Xavier Becerra, et al., No. 24-cv-00609-P (N.D. Tex. 2025) significantly alters the primary mechanism used by the U.S. Department of Health and Human...more
On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more
An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more
On May 28, 2025, the United States Tax Court held that the limited partners of a limited partnership providing investment management services to various investment funds were not limited partners within the meaning of...more
Denham Capital Management LP (“Denham”), a private equity firm, has appealed the recent U.S. Tax Court decision that declined to revisit its interpretation of the “limited partner exception” under the Self-Employment...more
On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more
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
Le Tribunal administratif de Strasbourg rejette l’opposabilité de la doctrine administrative autorisant l’application du régime mère-fille aux intérêts financiers considérés comme excédentaires à la suite d’un contrôle (TA...more
One of the first rules of business is that you don’t leave money on the table. That adage is equally important in tax matters. Taxpayers can leave behind funds by failing to follow the rules. The importance of compliance with...more
The South Carolina Court of Appeals determined that Duke Energy Corporation (“Duke”) was entitled to claim nearly $25 million in investment tax credits on its 1996 to 2014 South Carolina income tax returns, as the investment...more
Consistent with the decisions in several other states interpreting the Uniform Division of Income for Tax Purposes Act’s (“UDIPTA”) definition of nonbusiness income, an Arkansas Circuit Court concluded that gains from the...more
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
La décision récente rendue dans l’affaire 1164708 B.C. Ltd. v. British Columbia (l’« affaire 1164708 B.C. Ltd. ») traite de l’applicabilité de la taxe supplémentaire sur les transferts de biens (property transfer tax) (la «...more
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
La Cour administrative d'appel de Paris rappelle à l'administration fiscale son obligation de motivation de la réponse aux observations du contribuable sous peine d'entacher la procédure d'irrégularité (CAA Paris, 13 février...more
In a victory for taxpayers across the nutmeg state, the Connecticut Supreme Court recently held in 7 Germantown Rd., LLC v. City of Danbury, No. 21024, 2025 WL 309848 (Conn. Jan. 28, 2025) (“Germantown”) that the appraisal...more
Recently, in Rawat v. Commissioner, the D.C. Circuit reversed the Tax Court decision and held that a foreign partner would not be subject to U.S. tax on selling an interest in a partnership with “hot assets” subject to §...more
Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more
The Pennsylvania Supreme Court recently issued a split decision in an unusual case where the Pennsylvania Department of Revenue (the Department) sided with the taxpayer against the commonwealth Office of Attorney General...more
Summary: This is a case of first impression concerning the meaning of “newly discovered or previously unavailable evidence” as contemplated by I.R.C. § 6015(e)(7)(B): “Any review of a determination made under this section...more
Sometimes, yes. At least that’s one takeaway from the argument in a recent U.S. Supreme Court case, Boechler, P.C. v. Commissioner of Internal Revenue. ...more