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Gore Decided: Unitary Nexus Rejected; Economic Substance Test Clarified

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

Legal Alert: Maryland Court of Appeals: Out-of-State Delaware Holding Companies Licensing Patents to Parent Company Doing Business...

Today, the Maryland Court of Appeals held that Maryland may tax out-of-state Delaware holding companies that license patents to their parent company, which was doing business in Maryland. Gore Enterprise Holdings, Inc. v....more

Virginia Adopts Narrow Definition of “Royalty” for Purposes of its Intangible Expense Add-Back

In a recent ruling, the Virginia Department of Taxation determined that payments made by a taxpayer to an affiliated corporation were not "royalty" payments and should not have been added back to the taxpayer’s Virginia...more

Investors Plead Guilty to Rig Bids at New Jersey Municipal Tax Auctions

Investors Plead Guilty to Rig Bids at New Jersey Municipal Tax Auctions by Frank L. Brunetti on October 3, 2013 Two financial investors who purchased municipal tax liens pleaded guilty today for their roles in a...more

IRS Begins Crackdown of Small Businesses

IRS Begins Crackdown of Small Businesses by Joseph M. Donegan on September 13, 2013 Small businesses may face increased scrutiny from the Internal Revenue Service, which recently announced that it believes small...more

The IRC §409A Minefield

The IRC §409A Minefield by James F. McDonough, Jr. on September 11, 2013 Tax professionals frequently encounter non-qualified deferred compensation plans (“NQDCA”) in the context of an estate or business. NQDCA’s...more

Kodak Receives Final Approval to Make Bankruptcy Emergence

Kodak Receives Final Approval to Make Bankruptcy Emergence by Joel R. Glucksman on September 5, 2013 Photography pioneer Eastman Kodak Co. has experienced a rough 19 months after seeking Chapter 11 bankruptcy protection...more

NCAA’s Request to Delay O’Bannon Lawsuit Causes More Complex Litigation

NCAA’s Request to Delay O’Bannon Lawsuit Causes More Complex Litigation by Anthony Caruso on August 30, 2013 The National Collegiate Athletic Association has petitioned a federal court to delay the Ed O'Bannon lawsuit...more

Spouses Should Be Aware of ‘Gift-Splitting’ Criteria when Gifting Assets

Spouses Should Be Aware of ‘Gift-Splitting’ Criteria when Gifting Assets by Frank L. Brunetti on August 26, 2013 Lawmakers' decision to both set the estate tax at $5.25 million for 2013 and increase the annual gift tax...more

What A Tax Attorney Can Do for You: Understand How Apple, Inc. Legally Does Not Pay Income Tax

When Apple Inc., disclosed that it has not paid any corporate income tax over the past 4 years, it got the government’s attention. Hailed before the Senate, Apple is confident in their tax position because, it is legal. ...more

Capital Infusion: Private Equity Update - May 2013

In This Issue: - DIGGING DEEPER: A Guide to Health Care Regulatory Due Diligence in Private Equity Deals 1 - Policy Spotlight: Affordable Care Act 6 - Case Spotlight: Best Practices in Down-Round Financings &...more

Inside M&A - Spring 2013

Top Five Traps for the Unwary in Spin-Offs - A wave of corporate breakups has swept through the United States over the last few years as investors have taken notice of the fact that smaller companies focused on a...more

The UK Patent Box – Clawing Some Money Back from the Taxman

As of April 1st, companies paying UK corporation tax can take advantage of a new tax regime, dubbed the “Patent Box,” to reduce their tax burden. Here we explain why this new regime has been put in place and how and why it...more

W.L. Gore’s Impact on Pending Maryland Cases and Audits

In a case decided late last month, Comptroller of the Treasury v. Gore Enterprise Holdings, Inc. and Future Value, Inc., Nos. 1696 and 1697 (January 24, 2013), the Maryland Court of Special Appeals held that patent royalties...more

Countdown to The Introduction of The New Patent Box Regime

From 1 April 2013, UK companies will be able to elect into a new regime that applies a lower rate of corporation tax to profits from qualifying intellectual property (IP) rights. The relief will be phased in, culminating on...more

IRS Issues Guidance on Outbound Transfers of Intangible Property in Asset Reorganizations

In Notice 2012-39 (the “Notice”), the IRS issued guidance announcing its intention to issue regulations with respect to certain transfers of intangible property by a U.S. corporation to a foreign corporation in a...more

Doing Business in Poland

Table of Contents: - Overview...1 - Forms of Entity.... 1 - Establishing A Business...2 - Specific Form of Doing Business In Poland-Direct Sales...4 - Dispute Resolution Mechanism... 5 - Labor Matters and...more

Inside the (Patent) Box: UK Government introduces beneficial tax regime on patent income

Beginning on 1 April 2013, the UK Government will reduce the rate of corporation tax payable in the UK on profits arising from patents and some other forms of intellectual property (“IP”). The reduced tax rate implemented by...more

Strategic Intellectual Property Offshoring Through Outsourcing

Traditionally intellectual property (IP) offshoring has been used by multinational corporations as a way to reduce their global effective tax rates by holding their IP in low tax offshore jurisdictions. The 2009 relocation by...more

Incorporating in Armenia

The article outlines the basic features of Armenian corporate law. Fundamentals of corporate formation, administration and other aspects of corporate activities are summarized in a few short paragraphs....more

"Beneficial Owner" - CRA'S Assessment Of Velcro Doesn't Stick

The Tax Court has once again considered the meaning of the phrase “beneficial owner” for purposes of the tax treaty between Canada and the Netherlands. It has also once again ruled in favour of the taxpayer in...more

What You Need to Get Done Now If You Want to Sell Your Company in 2012

One of today’s most discussed political topics is the expected expiration of the Bush tax cuts after December 31, 2012. If Congress doesn’t act, among other things, the individual U.S. federal income tax rate...more

Bipartisan Push for Royalty Addbacks

In January 25th, Pennsylvania House Members Dave Reed and Eugene DePasquale, together with 62 bipartisan cosponsors, introduced legislation (HB 2150, PN 3019) to disallow deductions under Pennsylvania’s Corporate...more

M&A Agreements: Opportunities And Perils In Asset Acquisitions

Table of Contents: I. INTRODUCTION ... 1 II. ALTERNATIVE STRUCTURES FOR TRANSFERS OF BUSINESSES ...... 3 A. Common Threads; Alternatives ... 3 B. Mergers and Consolidations ... 4 C. Purchases of Shares... 5 D....more

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