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Rivkin Radler LLP

Tax Authorities of the World Unite? Not Quite, But the IRS Joins the Movement to Tax the Rich

Rivkin Radler LLP on

Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key instrument . . . that governments have at their...more

Vedder Price

HMRC's slice of Italian restaurant's restructuring plan is big enough, finds English court

Vedder Price on

Summary - On 5 July 2023 the English High Court handed down its judgment to In the matter of Prezzo Investco Limited and In the matter of the Companies Act 2006 [2023] EWHC 1679 (Ch), another case (hot on the heels of The...more

Barnea Jaffa Lande & Co.

Reporting Methods – “Accrual Basis” or “Cash Basis”

The district court recently ruled that when determining a business’s correct reporting method to the Israel Tax Authority (ITA)—on an accrual or a cash basis—it is insufficient to examine the technical question of a...more

Holland & Knight LLP

Silencio administrativo positivo en materia tributaria en Colombia

Holland & Knight LLP on

La Sección Cuarta del Consejo de Estado de Colombia, en sentencia del 7 de diciembre de 2022, expediente #26546, precisó que el silencio administrativo positivo en materia tributaria también se configura cuando el acto...more

A&O Shearman

No illegal State aid had been granted by Luxembourg to Fiat according to the Court of Justice of the European Union

A&O Shearman on

On 8 November 2022, in the case Luxembourg and Fiat Chrysler Finance Europe v Commission, the Court of Justice of the European Union (the Court) annulled the judgment of the General Court as well as the decision of the...more

BCLP

German federal ministry of finance requires disclosure in cases of licensing of IP registered in Germany

BCLP on

Even without a German nexus, in cases of a licensing of right registered in Germany an application/disclosure before 30 June 2022 might be necessary. ..According to the German Federal Ministry of Finance (BMF) the...more

BakerHostetler

[Podcast] When State Tax Agencies Speak from Both Sides of the Mouth

BakerHostetler on

In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more

Freeman Law

State and Local Tax Voluntary Disclosure

Freeman Law on

This article is the second of a three-part series regarding the State and Local Tax consequences of doing business in multiple states.  This article will discuss Voluntary Disclosure, Part 1 discussed Nexus and Part 3 will...more

A&O Shearman

Rights granted abroad – Withholding tax due in Germany?

A&O Shearman on

Draft bill published on 19 November 2020 offers hope that an unnecessary tax discussion may be brought to an end A German tax issue has been causing great uncertainty among international corporates since spring 2020: Are...more

Morrison & Foerster LLP

German Registered IP: New Taxation Of Transactions Between Non-German Parties

In a decree published November 6, 2020, the German tax authorities confirmed their view that transactions between non-German parties (e.g., between two U.S. companies) are generally taxable in Germany, if this income is...more

Williams Mullen

Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind

Williams Mullen on

Tax partners Stephanie Lipinski Galland and Kyle Wingfield summarize what you can do if you have not filed your state and local taxes or if you are unable to pay your tax bills due to the COVID-19 pandemic. Topics include...more

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