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Tax Audits Taxation Tax Liability

Rivkin Radler LLP

Applying the Federal Priority Statute to The Attorney as Client’s “Corporate Executive”

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Over their career, every tax practitioner has had many client-taxpayers against whom a government’s taxing authority – be it federal, state, or local – has asserted and then assessed a tax deficiency. There are many...more

Mayer Brown

TBU | Offset of Taxes Paid Abroad by Controlled and Affiliated Companies – RFB Interpretative Declaratory Act No. 1/2026

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On January 23, 2026, the Brazilian Federal Revenue Service (“RFB”) published Interpretative Declaratory Act (“ADI”) No. 1/2026, which addresses the use of taxes paid abroad by directly or indirectly controlled or affiliated...more

Mayer Brown

Supplementary Law No. 225/2026: Taxpayers' Defense Code

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On January 9, 2026, the final text of the Supplementary Law ("LC") No. 225/2026 was published in the Official Gazette of the Federal Government, which launches the Taxpayers´ Defense Code (the “Code”), establishing...more

Mayer Brown

Décision du Conseil d’Etat sur l’ordre d’imputation des déficits reportables en avant

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Le Conseil d’Etat tranche la question de l’ordre d’imputation des déficits reportables en avant : il retient une imputation selon un ordre strictement chronologique et en tire les conséquences pour l’application des règles de...more

Rivkin Radler LLP

Escape from New York – It’s Not That Easy

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It’s not at all unusual to encounter the owner of a New York business who dreams about leaving the State. The reasons often given for the desired move include, among others, the cost of doing business in New York, the State’s...more

Cole Schotz

Snowbirds’ Wings Clipped by New York Tax Appeals Tribunal

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In a recent decision, the New York Tax Appeals Tribunal issued a sharp reminder to ‘snowbirds’ that changing domicile is about substance, not paperwork. In Matter of John J. Hoff & Kathleen Ocorr-Hoff, DTA No. 850209 (N.Y....more

Epstein Becker & Green

The 409A Horror Show: Don’t Let Year-End Turn Into a Tax Nightmare

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As year-end approaches, it is an opportune time for companies to run an internal audit of their nonqualified deferred compensation plans to flag any potential violations of IRC Section 409A (“Section 409A”)....more

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

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Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Buckingham, Doolittle & Burroughs, LLC

Ohio State Bar Association Taxation Committee - Sales/Use Tax Subcommittee Report - February 2023

I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more

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