Podcast: Cum-Ex Dividend Trade Investigations
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Venture Capital Trends: East Meets West – Lewis Geffen, Co-chair, Venture Capital Practice
What Individuals and Businesses Need to Know About the American Taxpayer Relief Act
The California State Legislature overturned Microsoft’s recent win at the Office of Tax Appeals, which held that the gross amount of dividends received from foreign affiliates outside its water’s-edge group should be included...more
The California Office of Tax Appeals (OTA) denied a request for rehearing of a July 2023 OTA opinion favorable to Microsoft Corp. that could have wide-ranging impacts for a water's edge filer in California, particularly one...more
The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more
The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more
A recent pair of decisions by the California Office of Tax Appeals examined the tax treatment of special dividends paid in connection with the acquisition of a corporate target. Private company acquisitions are...more
On October 30, 2019, the British Columbia Court of Appeal upheld the rectification of an erroneously calculated capital dividend account, saving the corporate taxpayer from a punitive 60% tax. ...more
The Upper Tribunal (Tax and Chancery Chamber), the UK’s second level tax appeal court, have just published their judgement in the McQuillan case, which considered whether shares with no right to dividends or any other profits...more
State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more