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Subsidiaries Tax Refunds

McDermott Will & Emery

Focus on Tax Controversy - Summer 2015

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The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

Ballard Spahr LLP

Supplemental Interagency Guidance on Tax Allocation Agreements

Ballard Spahr LLP on

The federal bank regulators recently issued additional guidance on intercompany income tax allocation agreements between holding companies and their depository institution subsidiaries. Intended to clarify the ownership of...more

McDermott Will & Emery

French 3 Per Cent Tax on Distributions: French Subsidiaries of Foreign Companies Should Consider Claiming a Refund

McDermott Will & Emery on

Scope of The 3 Per Cent Tax - The 3 per cent tax is levied on dividend distributions and/or deemed dividend distributions by French companies, French permanent establishments and other French entities that are liable...more

McDermott Will & Emery

The 3M Case: Can the IRS Overrule the Supreme Court?

McDermott Will & Emery on

3M Company’s challenge to the validity of Treas. Reg. § 1.482-1(h)(2), if successful, could result in refunds for taxpayers that previously followed the Internal Revenue Service’s regulatory guidance purporting to overrule...more

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