Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key instrument . . . that governments have at their...more
Summary - On 5 July 2023 the English High Court handed down its judgment to In the matter of Prezzo Investco Limited and In the matter of the Companies Act 2006 [2023] EWHC 1679 (Ch), another case (hot on the heels of The...more
The district court recently ruled that when determining a business’s correct reporting method to the Israel Tax Authority (ITA)—on an accrual or a cash basis—it is insufficient to examine the technical question of a...more
La Sección Cuarta del Consejo de Estado de Colombia, en sentencia del 7 de diciembre de 2022, expediente #26546, precisó que el silencio administrativo positivo en materia tributaria también se configura cuando el acto...more
On 8 November 2022, in the case Luxembourg and Fiat Chrysler Finance Europe v Commission, the Court of Justice of the European Union (the Court) annulled the judgment of the General Court as well as the decision of the...more
Even without a German nexus, in cases of a licensing of right registered in Germany an application/disclosure before 30 June 2022 might be necessary. ..According to the German Federal Ministry of Finance (BMF) the...more
In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more
This article is the second of a three-part series regarding the State and Local Tax consequences of doing business in multiple states. This article will discuss Voluntary Disclosure, Part 1 discussed Nexus and Part 3 will...more
Draft bill published on 19 November 2020 offers hope that an unnecessary tax discussion may be brought to an end A German tax issue has been causing great uncertainty among international corporates since spring 2020: Are...more
In a decree published November 6, 2020, the German tax authorities confirmed their view that transactions between non-German parties (e.g., between two U.S. companies) are generally taxable in Germany, if this income is...more
Tax partners Stephanie Lipinski Galland and Kyle Wingfield summarize what you can do if you have not filed your state and local taxes or if you are unable to pay your tax bills due to the COVID-19 pandemic. Topics include...more