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 New Mexico Court of Appeals has held that a multinational oil and gas production company did not constitute a “unitary corporation” with its foreign subsidiaries, pursuant to statutory carveout language regarding the term...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
Missouri law allows taxpayer corporations to reduce their Missouri-taxable income by the amount of “corporate dividends from sources within Missouri.” The statute is said to be a legislative policy choice to encourage...more
Double Tax- The shareholders of C corporations have long sought legitimate operational and transactional structures by which they may reduce the double tax hit that is realized when such a corporation distributes its...more
The New Jersey Division of Taxation issued a notice on November 5th solving the “trapped dividend exclusion” issue faced by many taxpayers as they prepared to file their first New Jersey combined Corporate Business Tax (CBT)...more
The Tax Cuts and Jobs Act (TCJA) brought sweeping changes to the U.S. international tax system. Along with those changes came substantial taxpayer uncertainty as to how the TCJA’s rules apply to their unique circumstances....more
The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general rule, such as where a taxpayer files a false return or omits more than 25...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
The Hinds County Chancery Court recently issued an opinion in AT&T Corp. v. Miss. Dep't of Revenue finding that Mississippi's dividend exclusion statute unlawfully discriminates against interstate commerce and is therefore...more
A Mississippi trial court has again found unconstitutional the state’s dividend exclusion statute, which disadvantages certain multistate taxpayers as compared to solely Mississippi taxpayers. This result comes from AT&T’s...more