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Double Taxation Apportionment

Eversheds Sutherland (US) LLP

Wynne’s First Casualty: First Marblehead Corp. v. Commissioner

Today, the U.S. Supreme Court vacated the decision of the Massachusetts Supreme Judicial Court (SJC) in First Marblehead Corp. v. Commissioner of Revenue (First Marblehead) and remanded the case back to the court for...more

McDermott Will & Emery

Can Taxpayers Find an Advantage in Vodafone Nowhere Income Argument?

McDermott Will & Emery on

It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900...more

McNees Wallace & Nurick LLC

PA Supreme Court Issues Business / Nonbusiness Income Decision

The Pennsylvania Supreme Court has held that a taxpayer’s gain from the sale of timberland was apportionable business income using the “functional test” of Pennsylvania’s amended definition of “business income.” Glatfelter...more

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