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Tax Code Tax Liability

Cadwalader, Wickersham & Taft LLP

Liberty Global Appeals Economic Substance Doctrine Ruling

In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more

Bowditch & Dewey

Olympic Medals and Income Tax

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The 2024 Paris Olympics are in full swing, and it is never too early for U.S. athletes to consult with their tax advisor. As was done in 2021, the United States Olympic & Paralympic Committee has pledged to award U.S....more

Cadwalader, Wickersham & Taft LLP

The Supreme Court Has Saved the Tax Code for Now and Left Room for Moore

In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT), saving a significant portion of the current tax code for now. The question in front of the Court was whether...more

Mayer Brown

Measure ULA Update: Reported Revenue, Applicability to Foreclosures and Legal Challenges

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In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...more

Bowditch & Dewey

Spousal Relief From Joint Tax Liability

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As a general rule, when a married couple files a joint tax return, they are jointly and severally liable for the entire tax. But what happens if one spouse failed to report income and the other spouse did not know or have...more

Kelley Drye & Warren LLP

Court of Appeals Reverses Tax Court’s Farhy Decision, But Opportunities Remain to Challenge Penalties for Failures to Report...

As noted in our prior advisory, U.S. citizens and residents who receive gifts exceeding certain thresholds from foreign persons must generally report such gifts to the IRS on Form 3520, and the IRS does not hesitate to impose...more

Morgan Lewis

Biden Highlights IRS Plans to Audit Corporate/Partnership Jet Use in State of the Union Address

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In his State of the Union address, President Joseph Biden targeted tax breaks for corporations and wealthy individuals who use private jets as part of a broader goal to make big corporations and the wealthy pay “their fair...more

Williams Mullen

Hoops, LP: Seventh Circuit Denies Deferred Compensation Deduction in Taxable Asset Sale - Upsetting Common Understanding of Timing...

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On August 9, 2023, the Seventh Circuit Court of Appeals in Hoops, LP and Heisley Member, Inc., Tax Matters Partner vs. Commissioner of Internal Revenue, affirmed the Tax Court’s 2022 decision denying a deduction to a plan...more

Nossaman LLP

Los Angeles Office of Finance Clarifies Exemptions from “Mansion Tax”

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The Los Angeles Office of Finance (Office of Finance) has released a new FAQ confirming that real property transfers that are exempt from the current City documentary transfer tax (to which the FAQ refers as the “Base Tax”)...more

Holland & Knight LLP

DIAN Colombia: No compensación de pérdidas en integración de sucursales de sociedad extranjera

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En Oficio #1356 del 9 de noviembre de 2022, la Dirección de Impuestos y Aduanas Nacionales (DIAN) señaló que la integración en Colombia de dos sucursales de sociedades extranjeras, como resultado de una fusión entre sus dos...more

Freeman Law

Tax Residency Status Modification: Mexican Tax Implication

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For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living. And in an increasingly global...more

Freeman Law

Texas Tax Roundup | November 2022: What’s a Franchise Tax?

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Hey everybody! Welcome back to another for another edition of Texas Tax Roundup! Hope y’all had a happy Thanksgiving! We got some franchise tax apportionment, some sales and use tax in the oil and gas industry, and some...more

Allen Matkins

Attention Property Owners: Los Angeles and Santa Monica Approve ‘Mansion Tax’ Ballot Measures, Increasing Transfer Taxes on Sales...

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Residents of Los Angeles have approved Measure ULA, a ballot measure widely known as the “Mansion Tax,” which increases transfer tax rates on real estate sales valued at $5 million or more. Prior to Measure ULA, real estate...more

Cadwalader, Wickersham & Taft LLP

Getting the Fiats Straight: CJEU Annulled State Aid Decision against Fiat

On 8 November 2022, the Court of Justice of the European Union (the “CJEU”) set aside the EU General Court’s judgment of 2019 and annulled the European Commission’s State aid decision of 2015, which held that Luxembourg...more

Franczek P.C.

Illinois Dept. of Revenue Releases Final 2021 Cook County Equalization Factor

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On Tuesday, the Illinois Department of Revenue released the final 2021 Cook County equalization factor.  The factor (sometimes referred to as the multiplier) for 2021 is 3.0027.  The tentative factor released in June was...more

Paul Hastings LLP

Tax Avoidance or Not: Restructuring of Multinational Group Companies with use of Intra-group Loan — Deductibility of Interest...

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Transactions within a corporate group can sometimes achieve reduction of tax obligations, regardless of whether or how much such result was intended. One typical way observed is to extend an international intra-group loan by...more

Freeman Law

Texas Legislature Adds Suits After Redetermination as Option to Challenge State Tax Assessments

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In 2021, the Texas Legislature made it easier for taxpayers to challenge tax assessments without first paying the disputed amounts of tax due. Prior to this change, pay-to-play was the only game in town. Under pay-to-play, a...more

Freeman Law

Applying Texas Sales and Use Tax to New Construction and Real Property Repair and Remodeling Services

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One of the more complicated areas involving Texas sales and use tax is the taxation of various new construction and real property repair and remodeling services. Determining what’s taxed and what’s not requires delving...more

Freeman Law

Texas Tax Roundup | May 2022

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Howdy folks, and welcome back to another captivating installment of Texas Tax Roundup, where we gab about all things Texas taxes. Nothing court-side this month, just a bunch at the administrative level. Still, it’s...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

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Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Freeman Law

Texas Religious Organizations Property Tax Exemption

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Through nearly 20 years of law practice–15 of which have been focused on the representation of tax-exempt organizations–this writer has been involved in numerous seemingly simple–and some cutting edge–applications for...more

Akerman LLP - SALT Insights

Texas Supreme Court Rejects Texas Comptroller’s “Receipt-Producing, End-Product” Act Test for Sourcing Receipts from Services

On March 25, the Texas Supreme Court issued a highly-anticipated decision concerning the proper test to source receipts from services for purposes of Texas franchise tax. By statute, receipts from a “service performed in this...more

Rivkin Radler LLP

Tax Court’s Decision On Assumption of Liability in M&A – A Clean Block or Goaltending?

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Assumed Liabilities- If a taxpayer were to sell the assets that comprise the taxpayer’s business, they would realize gain if the amount realized by the taxpayer from the sale is more than the taxpayer’s adjusted basis for...more

Hogan Lovells

Identificación del Beneficiario Controlador como nueva obligación fiscal

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A partir de 1 de enero de 2022 las entidades legales en México deberán implementar procedimientos internos para obtener y conservar, como parte de los registros contables, la información de sus Beneficiarios Controladores....more

Hogan Lovells

Identification of the Beneficial Controller as a new tax liability

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Effective January 1, 2022, legal entities in Mexico must implement internal procedures to obtain and keep, as part of the accounting records, the information of their Beneficial Controllers....more

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