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Corporate Taxes Tax Tribunal Income Taxes

Eversheds Sutherland (US) LLP

Georgia’s 2024 legislative session: Sine Die tax legislation overview

The Georgia General Assembly passed several significant tax bills during the 2024 legislative session. Among them was the creation of a tax court in the judicial branch, a reduction of the individual and corporate income tax...more

Blank Rome LLP

Michigan Tax Tribunal Holds That Parent Properly Excluded its Wholly Owned Subsidiary from its Unitary Business Group Return

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Challenging a state corporate tax determination of a unitary business relationship between related corporations can be difficult. However, a recent decision of the Michigan Tax Tribunal shows that with good facts a business...more

Blank Rome LLP

Interest Payment Not Required to Be Added Back as Alabama’s Subject-To-Tax Exception Applied

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On July 28, 2022, the Alabama Tax Tribunal held that a corporation is not required to add back interest paid to a related entity as the recipient was subject to tax on that income in Ireland. This was so even though the...more

Eversheds Sutherland (US) LLP

Georgia’s 2022 legislative session ends with significant tax legislation

During the 2022 legislative session, the Georgia General Assembly passed significant tax legislation, including authorizing affiliated groups to file consolidated corporate income tax returns without prior approval from the...more

Proskauer - Tax Talks

Court of Appeal decides that Jersey companies were UK tax resident

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In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the...more

Proskauer - Tax Talks

Advisers’ fees non-deductible where management decisions made by parent company

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The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 10, Issue 8

Welcome to the latest issue of New York Tax Insights. In this issue we cover: ..The New York State Department of Taxation and Finance’s release of revisions to its draft business corporate franchise tax regulations for...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 10, Issue 5

2019-20 NYS BUDGET ENACTED, INCLUDING REAL ESTATE TRANSFER TAX INCREASES - On April 12, 2019, Governor Andrew M. Cuomo signed into law the New York State Budget Bill for the State’s 2019-20 fiscal year, which began on April...more

Proskauer Rose LLP

UK Tax Round Up - September 2018

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UK Case Law Developments - Entrepreneurs' relief – voting rights not imputed for equitable reasons - In George v HMRC, the First Tier Tribunal (FTT) decided that they could not apply the equitable principle that...more

Proskauer Rose LLP

UK Tax Round Up - January 2018

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The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) - The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more

Bradley Arant Boult Cummings LLP

Tax Tribunal Strikes Down Limitation on Credit for Taxes Paid to Other States

Readers may recall that Alabama Act 2012-427 permitted Alabama residents that owned interests in multistate pass-through entities (e.g., LLCs, partnerships, and S corporations) to claim a credit against their Alabama income...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 8

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

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