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Statutory Interpretation Internal Revenue Code (IRC) Corporate Taxes

Miller Canfield

Can Legislative History Restore a Repealed IRC Provision?

Miller Canfield on

Altria Group, Inc. v. United States, a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult...more

Freeman Law

Will a U.S. Tax Treaty Apply to a U.S. State’s-Imposed Tax?

Freeman Law on

Two countries form a treaty under the general principles of contract law. A fundamental aspect of contract law requires a meeting of the minds – a shared understanding of the agreed terms. Accordingly, unless expressly...more

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