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Tax Deductions Appeals

McDermott Will & Emery

Nebraska District Court Holds That GIL 24-19-1 is Not Afforded Deference

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Last week, the Lancaster County District Court granted the state’s motion to dismiss in COST v. Nebraska Department of Revenue. COST brought this declaratory judgment action to invalidate GIL 24-19-1, in which the department...more

White & Case LLP

Interest related to leveraged capital reduction or dividend distribution not always tax deductible, according to the Supreme Court

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The Supreme Court has ruled that interest on a loan contracted in order to carry out a capital reduction or a dividend distribution when the company lacks the liquidity to do so is not always deductible. It is crucial that...more

Nutter McClennen & Fish LLP

Debt-Financed Losses in S Corporations and Partnerships

Partners in partnerships are allowed to deduct operating losses in partnerships that their shareholder counterparts in S corporations cannot deduct. The difference results from a difference between partners and shareholders...more

McDermott Will & Emery

A Notice of Deficiency Is Not Set in Stone

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A recent case decided by the United States Court of Appeals of the Tenth Circuit reminds taxpayers to be aware that the Internal Revenue Service (IRS) is not necessarily locked in to the positions and arguments stated in the...more

Burr & Forman

Conservation Easements: Building Envelopes Doom Donation

Burr & Forman on

The Tax Court recently issued a full T.C. opinion which will impact a tremendous number of conservation easement donations. In Pine Mountain Preserve, LLLP v. Commissioner, 151 T.C. 4 (2018) the Tax Court found a reservation...more

Buckingham, Doolittle & Burroughs, LLC

Ohio Sales & Use Tax: Resale exemption denied where lease amongst related parties lacked a substantive business purpose.

Businesses commonly use what is referred to as a “dry lease” to obtain use of a corporate aircraft for several reasons. One benefit of these arrangements is the lessor’s ability to claim the resale exemption on the aircraft’s...more

Burns & Levinson LLP

In My Opinion: Alpenglow Botanicals v. United States

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If you read my most recent post on Section 280E of the Internal Revenue Code, you might have picked up on my disappointment with the Alpenglow opinion. Whether the conclusion is right or wrong, in my estimation, it could have...more

Fisher Phillips

Web Exclusive December 2017: The Top 14 Labor And Employment Law Stories

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It’s hard to keep up with all the recent changes to labor and employment law. While the law always seems to evolve at a rapid pace, there were an unprecedented number of changes each month in 2017. December was no different,...more

Proskauer Rose LLP

UK Tax Round Up - August 2017

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UK Tax News and Developments - Latest on the Finance (No 2) Bill 2017 - On 20 July 2017 the government announced in Hansard that the House of Commons will, on Wednesday 6 September 2017, be asked to approve the Ways and Means...more

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