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Income Taxes › Tax Liability › Double Taxation

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Cadwalader, Wickersham & Taft LLP

Burlington: Good News for the Secondary Debt Market

Cadwalader, Wickersham & Taft LLP on

In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

Holland & Knight LLP on

The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

Strafford

[Webinar] Tax Considerations for Foreign Rental Property: Holding Structures, Reporting Rental Income and Expenses, FTCs - March...

Strafford on

This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more

Cadwalader, Wickersham & Taft LLP

Pin-pointing Residence

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The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more

Freeman Law

Tax Court in Brief | Smith v. Comm’r | Closing Agreement and Malfeasance of Fact

Freeman Law on

Short Summary:  The case discusses the validity of a closing agreement and if a taxpayer can set aside such agreement under malfeasance or misrepresentation of fact....more

Proskauer Rose LLP

UK Tax Round Up - October 2022

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Welcome to the October edition of the UK Tax Round Up. October has been an extraordinary month in the UK, with political turbulence triggering reversals of many of the tax policies announced by the government at the end of...more

Bradley Arant Boult Cummings LLP

Tax Tribunal Strikes Down Limitation on Credit for Taxes Paid to Other States

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Readers may recall that Alabama Act 2012-427 permitted Alabama residents that owned interests in multistate pass-through entities (e.g., LLCs, partnerships, and S corporations) to claim a credit against their Alabama income...more

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