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Civil Procedure Tax Intellectual Property

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Partnering Perspectives - Summer 2017

As we implement the Eversheds Sutherland combination and expand our ability to serve clients around the globe, our US and international teams are working together to analyze issues impacting clients doing business in multiple...more

Amazon v. Commissioner: IRS Cost Sharing Buy-In Challenge Rejected Again

by Jones Day on

On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary... ...more

McDermott International Legal Highlights November 2016

by McDermott Will & Emery on

The New World of Global Tax Planning: a Checklist for Success - As all multinationals (MNEs) are discovering, domestic implementation of the recommendations set out in the base erosion and profit shifting (BEPS) final...more

California Supreme Court Denies BOE Petition for Review in Lucent Technologies

by McDermott Will & Emery on

Last week, the California Supreme Court denied the State Board of Equalization’s (BOE’s) petition for review in Lucent Technologies, Inc. v. State Bd. of Equalization, No. S230657 (petition for review denied Jan. 20, 2016)....more

California Court of Appeal Hears Oral Argument in Lucent Technologies

by Reed Smith on

On September 24, the Court of Appeal for the Second District heard oral argument in Lucent Technologies v. State Board of Equalization. The issue before the court was whether telephone switching software is exempt from sales...more

Marshmallow Justice: 10 Tales of Legal Fluff and Other Stuff

Just about one hundred years ago, Archibald Query of Somerville, Massachusetts invented the first commercial marshmallow cream, which he pedaled door-to-door in Union Square. Around 1917, he sold the recipe for $500 to two...more

ESPN Productions Scores Win with Indiana Tax Court’s Ruling Prohibiting Public Access to its Tax Returns and Trade Secrets

by Faegre Baker Daniels on

On April 9, 2015, ESPN Productions, Inc. recorded its biggest play of the day in the Indiana Tax Court, when the Court granted the Company’s request to seal from public disclosure tax returns, a production services agreement,...more

Pennsylvania Tax Developments - A Reed Smith Quarterly Update: March 2015

by Reed Smith on

This is a brief update on recent Pennsylvania tax developments. Governor Wolf’s FY16 Budget Proposal—combined reporting and more On March 3, Gov. Tom Wolf (D) presented his first budget address as Pennsylvania’s 47th...more

Australia: What is and is not a “royalty” for withholding tax purposes? Latest key court decision

by DLA Piper on

By Jock McCormack, James Newnham, Matthew Cridland and Eddie Ahn Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal...more

Gore Decided: Unitary Nexus Rejected; Economic Substance Test Clarified

by Reed Smith on

Today, the Maryland Court of Appeals issued its highly anticipated decision in Gore Enterprise Holdings, Inc. v. Comptroller of the Treasury; Future Value, Inc. v. Comptroller of the Treasury. The court held that under the...more

Where’s the Beef? Virginia Circuit Court Allows Wendy’s to Claim Exception to Addback for Royalties Paid to Affiliate

by Reed Smith on

A new opportunity may exist for franchisors to claim an exception to Virginia’s royalty addback statute based on a recent Circuit Court decision. In Wendy's International Inc. v. Virginia Dep't of Taxation, decided March...more

Let's Be Reasonable: Recent Federal Circuit Actions Follow Trend Toward E-Discovery Reform

The U.S. Court of Appeals for the Federal Circuit recently held that expenses associated with a third-party electronic database service can constitute taxable costs. In re Ricoh Co., Ltd. Patent Litig., No. 2011-1199,...more

Corporate and Financial Weekly Digest - November 18, 2011

by Katten Muchin Rosenman LLP on

In this issue; - FINRA Reminds Firms of Their Obligations Regarding the Supervision of Registered Persons Using Senior Designations - Broker Dealer and Investment Adviser Renewal Statements for 2012 Available on Web...more

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