Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
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Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
The November 30, 2023, opinion of a New York administrative law judge in In the Matter of the Petition of Edward A. and Doris Zelinsky upholds the state’s so-called income tax “convenience rule” with an expanded legal...more
Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises. The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more
If you own property in Michigan, then you just received (or will soon receive) a Notice of Assessment, Taxable Valuation and Property Classification from your local city or township. The phrase “THIS IS NOT A TAX BILL” is...more
Last week, Governor Murphy of New Jersey staked out a position on New York City’s congestion pricing proposal, stating that it “can’t be ‘on the backs of New Jersey commuters.’” “Whether it’s how we’re taxed by our...more
Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more
Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more
“Yes” to Art, “No” to Tax- Private patronage of the arts. For centuries, artists, museums, and galleries have depended, in no small part, upon the largesse of wealthy families. Today, as in the past, many of these...more
The New York State sales tax on “protective and detective services” has been given an expansive reading by the New York State Tax Appeals Tribunal in a decision involving information technology (“IT”) security services. In In...more
The New York State Tax Appeals Tribunal held that an information service was not subject to sales tax because although the service provider had the right to provide the information to others, it did not have the technical...more
A year and a half following the New York Court of Appeals’ significant 2019 decision in Matter of Wegmans Food Markets, Inc. v. Tax Appeals Tribunal of State of New York, 33 NY3d 587 (2019), New York continues to grapple with...more
Income & Franchise Taxes—Deductions - Massachusetts—Appeals Court Allows Deduction for Utility Taxes Paid to Indiana - The Massachusetts Appeals Court reversed a decision of the Appellate Tax Board and allowed Bay State...more
On December 26, 2019, in Matter of Mackenzie Hughes LLP v. New York State Tax Appeals Tribunal, the New York Supreme Court, Appellate Division, held that New York’s retroactive decertification of Qualified Empire Zone...more
UK investment managers paying fee rebates, loyalty bonuses or similar payments to UK investors and certain non-UK investors in collective investment schemes should note recent case law developments regarding the tax treatment...more
TRIBUNAL AFFIRMS DECISION SOURCING “OTHER BUSINESS RECEIPTS” TO WHERE THE WORK WAS PERFORMED - After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new...more
The decision by the New York City Tax Appeals Tribunal in Goldman Sachs Petershill Fund Offshore Holdings Corp (“Petershill Fund“), unfortunately, does not involve parachute pants or any reference to the “Running Man” dance....more
A SECOND APPELLATE COURT UPHOLDS THE CONSTITUTIONALITY OF NEW YORK’S STATUTORY RESIDENCY SCHEME - The New York Appellate Division, Third Department, has upheld the dismissal of a declaratory judgment action brought by...more
Appellate Court Holds That Furnishing of Pricing Information Is Not a Taxable Information Service - The Appellate Division has issued a potentially important decision regarding the sales tax exclusion for information...more
The Upper Tribunal (Tax and Chancery Chamber), the UK’s second level tax appeal court, have just published their judgement in the McQuillan case, which considered whether shares with no right to dividends or any other profits...more
Our August 2017 issue of New York Tax Insights covers these recent developments: Sale of Security Services to Property Manager for NYC Housing Authority Held Exempt from Sales Tax - The sale of security services by a...more
ALJ Holds that Executive Changed His Domicile to Paris and Was Not a New York Resident - A New York State Administrative Law Judge has held that an individual who retired as chief financial officer of Colgate-Palmolive...more
Local assessors are in the process of sending annual notices of real and personal property tax assessments to property owners/taxpayers, who must determine whether the assessments are correct and whether an appeal should be...more
New York City Tribunal Rejects City’s Attempt To Forcibly Combine Bank And Its Mortgage Subsidiary - The New York City Tax Appeals Tribunal, affirming a determination of the Chief Administrative Law Judge, has held that...more
Court Of Appeals Affirms Revocation Of Tax Exemption For Public Parking Facilities - Reversing a decision by the Appellate Division, the Court of Appeals has held in a 5-2 decision that a charitable organization is not...more