News & Analysis as of September 22, 2024

Income Taxes › Evidence

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

UK Government Calls for Evidence on the Reform of Carried Interest

Morgan Lewis on 8/2/2024

On 29 July, the UK government issued a call for evidence in connection with its proposed reform of the UK taxation of carried interest. Noting that the tax treatment of carried interest is the subject of considerable debate,...more

Tax Court in Brief | Thomas v. Comm’r | Interpretation of Section 6015(e)(7)(B): “Newly Discovered or Previously Unavailable...

Freeman Law on 2/20/2023

Summary: This is a case of first impression concerning the meaning of “newly discovered or previously unavailable evidence” as contemplated by I.R.C. § 6015(e)(7)(B): “Any review of a determination made under this section...more

Estimating Tax Deductions: The Cohan Rule

Freeman Law on 10/6/2021

The Cohan Rule: Tax Deductions with Incomplete Records - The “Cohan rule” is derived from the Second Circuit’s 1930 decision, Cohan v. Commissioner, which allowed the taxpayer to approximate travel and entertainment...more

FCA upholds reconsideration decision maintaining $100M+ award against Apotex for cefaclor patent infringement

Smart & Biggar on 8/2/2021

Update: On September 28, 2021, Apotex applied to the Supreme Court of Canada for leave to appeal (Docket No. 39851). On July 23, 2021, the Federal Court of Appeal (FCA) dismissed Apotex’s appeal of the Federal Court’s (FC)...more

Getting Counsel Involved Early can Save your Ohio Sales / Use Tax Refund

Buckingham, Doolittle & Burroughs, LLC on 9/6/2019

Recently, the Ohio Board of Tax Appeals (BTA) denied a taxpayer’s sales tax refund in part because it could not consider the taxpayer’s improperly submitted evidence. In Environmental Quality Management Inc. v. McClain, BTA...more

Court Rules that Wind Farm Did Not Provide Proof of Development Fee to Receive 1603 Cash Grant

McDermott Will & Emery on 6/27/2019

On June 20, 2019, the United States Court of Federal Claims published its long-awaited opinion in California Ridge Wind Energy, LLC v. United States, No. 14-250 C. The opinion addressed how taxpayers engaging in related party...more

Intellectual Property Bulletin - Summer 2018

Fenwick & West LLP on 7/11/2018

In This Issue - US Taxation of IP After Tax Reform - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury...more

Rectification in a Tax Context: The Intention Standard Prevails

Blake, Cassels & Graydon LLP on 11/3/2015

A drafting mistake in an agreement can result in significant and unintended tax consequences. In the recent case of Baytex Energy Ltd. v. Canada (Attorney General) (Baytex), the Court of Queen’s Bench of Alberta (Court)...more

Missing Transmittal Envelope Was Not The Intentional Spoliation Of Evidence Justifying Indiana Tax Court’s Dismissal Of Income Tax...

Faegre Drinker Biddle & Reath LLP on 10/2/2014

An Indiana gambler lost another hand in the latest ruling by the Tax Court on his continuing discovery disputes with the Indiana Department of Revenue. On September 18th the Court denied Nick Popovich’s motion for default...more

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Income Taxes › Evidence

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