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Due Process Corporate Taxes

Miller Canfield

Watch the Scope of Your IRS Closing Agreement

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The rules relating to delegated authority are complex. A taxpayer is well advised to ensure that the scope of a closing agreement the taxpayer signs is what the taxpayer expects, and that an IRS official who signs the...more

Freeman Law

Ninth Circuit Rejects Constitutional Challenges to Section 965 Tax

Freeman Law on

In Moore v. United States, the U.S. Ninth Circuit Court of Appeals recently rejected arguments that the mandatory repatriation tax imposed under section 965 of the Internal Revenue Code violated the Constitution’s...more

Eversheds Sutherland (US) LLP

No loss: Stricken by the Pennsylvania Supreme Court, the NOL deduction nevertheless is allowed 

In General Motors Corporation v. Commonwealth, the Pennsylvania Supreme Court held that the state’s prior flat $2 million cap on a corporate taxpayer’s net operating loss (NOL) deduction violated the state constitution’s...more

McDermott Will & Emery

BREAKING NEWS: New York Considers 5% Gross Receipts Tax on Almost Every Corporation

McDermott Will & Emery on

On January 21, A. 9112 was introduced in the New York Assembly. An identical Senate companion bill, S. 6102, has been referred to the Senate Budget & Revenues Committee after being introduced in May 2019. The bills would...more

Brownstein Hyatt Farber Schreck

Tax & Representation - September 2018

TAX TIDBIT - “So what do we have? Caddyshack II, Weekend at Bernie’s II, Jaws: The Revenge… The sequel is just about never as good as the original. In this case, I sure hope this Tax Scam 2.0 is just as popular as the...more

McDermott Will & Emery

Washington ALJ Upholds B&O Assessment on German Company’s Royalty Income

McDermott Will & Emery on

On May 31, 2016, the Washington Department of Revenue (DOR) Appeals Division released a Determination (No. 15-0251, 35 WTD 230) denying a German pharmaceutical company’s business and occupation tax (B&O) protest. The...more

Eversheds Sutherland (US) LLP

Court of Appeals Hears Michigan’s Compact Election Cases

The long saga of Michigan's Multistate Tax Compact election continued on Wednesday with oral argument before the Michigan Court of Appeals. A packed courtroom witnessed a 1.5 hour proceeding before an active three-judge...more

Morrison & Foerster LLP

‘Inherited’ Nexus And Other Extreme Nexus Theories

Nexus — whether a corporation has a sufficient connection such that it may be taxed by a state — is one of the most important issues in state tax. Various legal theories have been asserted (and are being asserted) to justify...more

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