Tax Law, Civil Procedure, Bankruptcy

Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk [Video]

by Bloomberg Law on 5/22/2013

May 22 (Bloomberg) -- AMF Bowling Worldwide Inc. and Ahern Rentals Inc. are prime examples of the frothy market where junk-bond investors are fearless in the face of risk, as Bloomberg Law's Lee Pacchia and Bloomberg News...more

California Court Finds Securitization Entities Subject to California Income Tax

by Marty Dakessian, Mike Shaikh, Kyle O. Sollie | Reed Smith on 5/13/2013

A California Superior Court has issued a decision with significant impact on financial services. In the case, Harley-Davidson, Inc. v. Franchise Tax Board, San Diego Superior Court Judge Joel Pressman held that...more

March 2013 - SALT Shaker Newsletter

by Mary Alexander, Andrew Appleby, Zachary Atkins, Madison Barnett, Todd Betor, Scott Booth, Christopher Chang, Timothy Gustafson, Sahang-Hee Hahn, Jessica Kerner, Pilar Mata, more +Kathryn Pittman, David Pope, Jack Trachtenberg | Sutherland Asbill & Brennan LLP on 4/1/2013

In this issue: - Delivered by Independent Contractors, Undelivered by P.L. 86-272: Order Fulfillment Activities Subject Out-of-State Seller to New York Corporation Franchise Tax - Everything’s Bigger in Texas,...more

United States of America v. Susquehanna Bank

Appellee's Brief

by Thomas Valkenet on 2/19/2013

The Internal Revenue Service appealed a grant of summary judgment favoring Mr. Valkenet's client, Susquehanna Bank. The Maryland bankruptcy court granted the bank's indemnity deed of trust priority over IRS tax liens by...more

No Oregon Income Tax Nexus For Company Owning Intangibles Used In State

by Gregg D. Barton, Robert (Bob) L. Mahon | Perkins Coie on 12/21/2012

A federal bankruptcy court judge has held that Washington Mutual, Inc. (WMI), a parent holding company that owned bank subsidiaries conducting business in Oregon, did not have nexus in Oregon by virtue of its ownership of the...more

Estate of Badii ex rel. Badii v. Metropolitan Hospice, Inc., C.A. No. 6192-VCP (Del. Ch. Mar. 12, 2012) (Parsons, V.C.)

by Potter Anderson & Corroon LLP on 3/19/2012

In this memorandum opinion, the Court of Chancery appointed a receiver for an insolvent corporation deadlocked over how to discharge a tax lien. Defendant Metropolitan Hospice, Inc. (“MHI”), a closely held corporation,...more

How long does the IRS have to collect taxes owed?

by George Bourguignon on 1/4/2012

If you have an outstanding tax debt and are curious if it can still be collected or if you want to know more about how long the IRS has to collect a tax, then you may want to take a look at this post! Contact: George E....more

Crown Wins GAAR Case in the Supreme Court of Canada: Copthorne Holdings Ltd. v. The Queen

by Dentons on 12/19/2011

On December 16, 2011, the Supreme Court of Canada released its latest General Anti-Avoidance Rule (GAAR) decision in Copthorne Holdings Ltd. v. Canada. The appeal was heard on January 21, 2011 by all nine of the Justices...more

A Privilege, not a Right - Court of Appeal refuses to extend Privilege to Accountants and non-lawyers

by Michael Axe on 12/13/2010

Michael Axe reports on the implications of the English Court of Appeal's decision that confidential communications between clients and their accountants are not protected from disclosure by Legal Professional...more