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California Tax Developments - A Reed Smith Quarterly Update (3rd Quarter 2014)

Case Updates - Court finds ownership of LLC membership interest does not constitute doing business in California On November 14, the Fresno County Superior Court determined that Swart, an Iowa-based corporation with a...more

MoFo New York Tax Insights - Volume 4, Issue 10 - October 2013

In This Issue: Despite Incorrect Advice from NYS Tax Department, Conference Request Held to Be Untimely; Corporate Officer Liable for Sales Tax Despite Creditor’s “Sweep Arrangement” with Corporation; Charter Yacht Not...more

A Month in UK Employment Law - January 2013

In This Issue: - 2013 – What's On the Horizon - Changes Confirmed - Changes Expected In 2013 But No Implementation Date ...more

Federal Court of Appeal: Canada Cannot Tax Treaty Income Twice

It is trite law that one of the main purposes of tax treaties is to prevent double taxation of the same income. In Canada this principle has often been treated with a grain of salt since Canadian domestic rules do not bar...more

Reuters: Corporations Face Long Odds in Tax Cases Heard by the United States Supreme Court – Situation Brighter in Canada

Reuters recently reported a study showing that corporations face very long odds in tax appeals heard by the United States Supreme Court. There were 919 income tax cases in the Supreme Court of the United States from 1909 to...more

Wealth Management Update - May 2012

A monthly report for wealth management professionals. In This Issue: - May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts...1 - Wandry v....more

High Net Worth Family Tax Report - April 2012, Vol. 7 No. 1

In This Issue: - $5,120,000 Lifetime Gift Tax Exemption Expiring Soon We recently circulated this article as a Special Client Alert. The resetting of the lifetime gift-tax exemption back to $1 million from...more

Court Finds Exigent Circumstances Warrant Appointment of Receiver for an Insolvent, Closely Held Corporation

The Delaware Chancery Court recently found that exigent circumstances necessitated the appointment of a receiver for an insolvent company under section 291 of the Delaware General Corporation Law (DGCL). The insolvent company...more

Advantages of Chapter 11

Companies that are facing seemingly insurmountable financial difficulties can often turn to chapter 11 for relief. Some of the key advantages of filing chapter 11 to successfully resolve a company’s financial woes...more

High Net Worth Family Tax Report, Vol. 6, No. 3

In This Issue: Congressional Super Committee Fails to Agree on Deficit Reduction Measures; Supreme Court to Resolve Statute of Limitations for Overstatements of Tax Basis; IRS Rules That Gift to Charity of Non-voting...more

10 Lessons from the Verizon Cases at the State Corporation Commission

In December of 2009, Verizon Communication, Inc.’s two “baby bell” subsidiaries in Virginia (Verizon Virginia, Inc. and Verizon South, Inc. — collectively, “Verizon”) filed applications to correct erroneous assessments of...more

An Update on the Availability of Relief under the US/UK Double Tax Treaty

The UK Courts have recently passed judgment in the latest stages of two significant cases regarding the availability of relief under the US/UK Double Tax Treaty. The first case, Swift, overruled an earlier decision allowing a...more

Be Ready to Pounce on a Texas Margins Tax Challenge

On July 29, 2011, Allcat Claims Services, L.P. (Allcat) and one of its individual partners filed a petition with the Texas Supreme Court seeking a declaratory judgment that the Texas margins tax (TMT) is unconstitutional...more

Mofo New York Tax Insights - May 2011 - Volume 2, Issue 5

In this issue: New Policy Offers Partial Relief from Controversial Responsible Person Liability; Successful Challenge to Assessment Does Not Entitle Taxpayers to an Award of Costs; Update on Barker Vacation Home Case; New...more

MoFo New York Tax Insights - Volume 2, Issue 4 - April 2011

In this issue: Tribunal Holds That Television Broadcaster Cannot Include Film in its Property Factor; Department Limits Application of Article 9-A Separate Accounting Election; Tribunal Grants State’s Motion to Reargue...more

Amendments To New York State False Claims Act Encourage Qui Tam Actions

On August 13, 2010, effective August 27, 2010, the New York legislature enacted Chapter 379, turbo-charging the New York False Claims Act (“FCA”), N.Y. State Fin. Law § 187 et seq., and providing would-be whistleblowers with...more

California Court of Appeal Permits Retroactive Taxes to Remedy Unconstitutional Discrimination; Upholds Post-Amnesty Penalty

The California Court of Appeal, First Appellate District, recently issued an opinion against the taxpayer in River Garden Retirement Home v. Franchise Tax Board, 2010 Cal. App. LEXIS 1146 (2010). The case presented two...more

Fix Your Tax Withholding and Finally Pay the Correct Amount

Do not be surprised with a large tax bill or loan the IRS your money interest free! Nationally recognized tax attorney explains what you need to do to adjust your Federal Tax Withholding. If you owe a lot or receive a large...more

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