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Corporate Taxes Tax Appeals Tax Court

Holland & Knight LLP

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

Holland & Knight LLP on

In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

Stikeman Elliott LLP

Raising New Arguments and Issues in Tax Litigation

Stikeman Elliott LLP on

Due to the complexity of Canadian tax law, it is not uncommon for taxpayers and the minister of national revenue to refine their respective positions and identify new arguments and issues in the course of the tax dispute...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 7

ALJ holds NYS Real Estate Transfer Tax Cannot Be Imposed on Sale of 45% Membership Interest in LLC - In an issue of first impression under the New York State real estate transfer tax, a New York State Administrative Law...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 5

Retroactive Application Of 2010 Statutory Amendment Permitted By Tribunal - Reversing the decision of an Administrative Law Judge, the New York State Tax Appeals Tribunal has upheld the constitutionality of retroactively...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, Issue 8 - August 2015

Court Of Appeals Affirms Revocation Of Tax Exemption For Public Parking Facilities - Reversing a decision by the Appellate Division, the Court of Appeals has held in a 5-2 decision that a charitable organization is not...more

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