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Internal Revenue Service Conflicts of Laws

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Haug Partners LLP

Don’t Get Caught In the Conflict: U.S. Versus Brazilian IP Transfer Pricing Rules

Haug Partners LLP on

During a 2019 Tax Executives Institute conference in Washington, D.C., the Commissioner of the U.S. Internal Revenue Service (IRS), Charles Rettig, proclaimed, “[I am] not a commissioner who believes that the IRS loses...more

Skadden, Arps, Slate, Meagher & Flom LLP

Challenging Tax Cuts and Jobs Act Regulations and IRS Guidance

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

Akerman LLP

Fourth District Court of Appeal Holds Sales Tax Against Florida Corporation on Out-of-State Sales is Unconstitutional

Akerman LLP on

In American Business USA Corp. v. Department of Revenue, Case No. 4D13-1472 (4th DCA November 12, 2014), the Fourth District Court of Appeal held that an assessment of sales tax pursuant to a provision in Florida's sales tax...more

Pullman & Comley - Labor, Employment and...

State Law Can Override Control Test for Employment

Past articles in this blog have discussed the control test for establishing an employment relationship as opposed to independent contractor status. Although government agencies such as the Department of Labor or IRS describe...more

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