News & Analysis as of

Tax Planning Appeals 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

Mayer Brown

Régime fiscal de faveur des BSPCE : non éligibilité en l’absence de rémunération du bénéficiaire

Mayer Brown on

La Cour administrative d’appel de Nancy précise la définition d’activité permettant de bénéficier du régime de faveur des BSPCE (CAA Nancy, 15 mai 2025, n° 22NC03173)....more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

Allen Barron, Inc. on

Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Morgan Lewis

Federal Fiscal Court Issues Two Rulings on the Requirements for a Consolidated Tax Group for Income Tax Purposes - Legal Insights...

Morgan Lewis on

In two rulings, the Federal Fiscal Court (BFH) ruled in favor of the taxpayer on the requirements for a consolidated tax group for income tax purposes. Managing holding partnership as controlling company (judgment of November...more

Blank Rome LLP

California Snags Former Resident for Tax Due on Stock Options

Blank Rome LLP on

Many employees receive stock options as compensation from their employers. When receiving this type of compensation, the state tax implications may not be at the forefront of the employees’ minds, especially where it may be...more

Morgan Lewis

Treasury and IRS Promulgate Final Regulations Governing Resolution of Federal Tax Controversies by the Independent Office of...

Morgan Lewis on

The US Department of the Treasury and the Internal Revenue Service (IRS) have released Final Regulations related to the resolution of federal tax controversies by the Independent Office of Appeals (Appeals), largely rejecting...more

Cadwalader, Wickersham & Taft LLP

Determining Significant Influence

On 17 January 2025, the United Kingdom Court of Appeal in HMRC v BlueCrest Capital Management (UK) LLP [2025] EWCA Civ 23 (“BlueCrest”) held that the First-tier Tribunal (“FTT”) and the Upper Tribunal (“UT”) had made a...more

Allen Barron, Inc.

The Appeal of an IRS Audit is Based Upon the Audit's Examination File

Allen Barron, Inc. on

Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more

Blank Rome LLP

Supreme Court of Arkansas Allows Corporation to Allocate Interest Expense Incurred to Fund Corporate Spin-off

Blank Rome LLP on

A recent Supreme Court of Arkansas decision has upheld a multistate corporation’s allocation to Arkansas of 100% of its interest expenses from borrowings to fund a spin-off. It also rejected as irrelevant the state’s attempt...more

Blank Rome LLP

Longtime Iowa Taxpayers Lose Out on Capital Gains Deduction

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The tax consequences of the sale of a business are complex, and strategizing to avoid one tax type may lead to unanticipated tax in another form. A recent decision of the Court of Appeals of Iowa illustrates this point. Clark...more

DarrowEverett LLP

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

DarrowEverett LLP on

In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

Freeman Law

The IRS Appeals Office

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The IRS Independent Office of Appeals (“IRS Appeals”) was established to provide an “independent” IRS function that is separate and independent from the IRS’s compliance functions that maintain responsibility for collecting...more

Buckingham, Doolittle & Burroughs, LLC

OSBA Sales & Use Tax Subcommittee Report Highlights Recent Cases - September 2019

The report highlights the recent changes to Ohio law requiring out-of-state sellers and marketplace facilitators to collect tax on sales into the state, as well as recent cases decided by the Ohio Board of Tax Appeals....more

Barnea Jaffa Lande & Co.

Dramatic Decision on the Taxation of Trusts in Israel

The Tel Aviv District Court handed down a decision a few days ago rejecting the Israel Tax Authority’s (ITA) position on the conveyance of real estate properties to trusts. This decision dramatically changes the taxation of...more

Ballard Spahr LLP

Fielding Case May Impact Taxation of Your Minnesota Trust

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Trustees of irrevocable trusts created by Minnesota residents may be impacted by a recent decision of the Minnesota Supreme Court. On July 18, 2018, in Fielding v. Commissioner of Revenue...more

Fenwick & West LLP

Intellectual Property Bulletin - Summer 2018

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In This Issue - US Taxation of IP After Tax Reform - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury...more

Coblentz Patch Duffy & Bass

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

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