Corporate Taxes, Subsidiaries, Income Taxes

Can Legislative History Restore a Repealed IRC Provision?

Miller Canfield on 2/16/2024

Altria Group, Inc. v. United States, a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult...more

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on 1/3/2018

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Mississippi Supreme Court Finally Disconnects The Line On Dividend Exclusion Statute In The AT&T Case

Butler Snow LLP on 11/10/2016

In a previous article, we summarized AT&T’s 16-year effort, in two separate lawsuits, to have declared unconstitutional two Mississippi income tax statutes on the alleged basis that they placed a greater tax burden on AT&T...more

The Qualified Subchapter S Subsidiary Election – A Primer and Beyond

Foster Garvey PC on 9/23/2016

Mr. Brant’s article offers readers a broad overview of the QSub election and a review of the history surrounding its statutory creation. In addition, it provides a rather in-depth discussion of the QSub qualification...more

Brexit: Key Tax Implications for Alternative Investment Funds and Investment Managers

Akin Gump Strauss Hauer & Feld LLP on 6/27/2016

The result of the UK’s referendum of 23 June 2016 was announced today as a victory for ‘Brexit’ - in other words, for the UK to exit the European Union. This decision is expected to have significant ramifications for the...more

Focus on Tax Controversy - Summer 2015

McDermott Will & Emery on 7/15/2015

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

State Revenue Departments Misapplying Federal Tax Law

McDermott Will & Emery on 9/10/2014

State income tax laws generally build on federal tax law. The typical pattern is to begin the calculation of state taxable income with federal taxable income and then to modify it by adding or subtracting items where state...more

Corporate Taxes › Subsidiaries › Income Taxes