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Income Taxes › Tax Tribunal

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... more +
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 -
Cadwalader, Wickersham & Taft LLP

“Ephemeral” Payments and Beneficial Entitlement

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Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises.  The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more

Eversheds Sutherland (US) LLP

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

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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

Pillsbury - SeeSalt Blog

New York State Tax Appeals Tribunal Rejects Sourcing of Partnership Income to that Partnership’s Operating Location

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The New York State Tax Appeals Tribunal (Tribunal) held that a taxpayer’s distributive share income from a partnership was intangible income properly sourced to the taxpayer’s residence and not to the location of the...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

Bradley Arant Boult Cummings LLP

New Tax Tribunal Ruling on Change-of-Residency Challenges

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There seems to be an increased number of so-called “residency audits” being conducted by the Alabama Department of Revenue (ALDOR), as well as by other state tax authorities. These audits often result from the taxpayer filing...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

Rivkin Radler LLP

New York to Taxpayer: “Forget What the Feds Said, You’re a ‘Responsible Person"

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Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more

Rivkin Radler LLP

Statutory Residence in New York: Time to Rethink the “Permanent Place of Abode” Test?

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Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more

Eversheds Sutherland (US) LLP

Georgia’s 2022 legislative session ends with significant tax legislation

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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

Cadwalader, Wickersham & Taft LLP

Mixed Membership Partnerships: A Salient Reminder

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Two differently constituted First-tier tribunals (FTTs) recently decided that amounts allocated to a corporate member of a limited liability partnership (LLP) were individually subject to income tax under the “miscellaneous...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

Proskauer - Tax Talks on

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

Dechert LLP

Financial Services Quarterly Report - Third Quarter 2019: Developments in the UK Tax Treatment of Fee Rebates and Trail...

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UK investment managers paying fee rebates, loyalty bonuses or similar payments to UK investors and certain non-UK investors in collective investment schemes should note recent case law developments regarding the tax treatment...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 10, Issue 9

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TRIBUNAL AFFIRMS DECISION SOURCING “OTHER BUSINESS RECEIPTS” TO WHERE THE WORK WAS PERFORMED - After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 10, Issue 8

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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

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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

Bradley Arant Boult Cummings LLP

Impact of Check-the-Box Conformity on State Tax Appeal Procedures – Who’s the Real Taxpayer Here? - SALT Alert: Alabama Edition

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In a case of first impression by an Alabama appellate court, the Alabama Court of Civil Appeals recently considered the appeal of the Alabama Department of Revenue (ADOR) of an adverse circuit court ruling involving whether...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 9, Issue 8

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APPELLATE COURT DISMISSES CONSTITUTIONAL CHALLENGE TO NEW YORK’S STATUTORY RESIDENCY SCHEME - The New York Appellate Division, First Department, finding that the U.S. Supreme Court’s 2015 decision in Comptroller of the...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

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 3

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ALJ Finds CEO Changed Domicile from New York City to Texas - A New York State Administrative Law Judge has held that the CEO of Match.com (“Match”) changed his domicile from New York to Texas for New York State and City...more

Dechert LLP

HMRC Publishes Guidance on the Tax Treatment of Clawback of Remuneration in the UK

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Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...more

Bradley Arant Boult Cummings LLP

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

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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

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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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