News & Analysis as of

Tax Deductions Tax Appeals

Cadwalader, Wickersham & Taft LLP

Complex Borrowing and Group Structures

The Court of Appeal’s (“CA”) ruling in April 2024 in the case of BlackRock Holdco 5 LLC v HMRC (“BlackRock”) considered the deductibility of interest on a $4 billion intra-group loan put in place as part of the funding...more

McDermott Will & Emery

Microsoft Scores Massive Win in California, Opens the Door for Others Nationwide

McDermott Will & Emery on

The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more

Rivkin Radler LLP

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

Rivkin Radler LLP on

Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more

BakerHostetler

[Podcast] When State Tax Agencies Speak from Both Sides of the Mouth

BakerHostetler on

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

McDermott Will & Emery

Weekly IRS Roundup November 11 – 15, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 11–15, 2019. November 11, 2019: The IRS released Delegation Order 30-9 announcing the...more

Foster Garvey PC

While Some Parents May Not Agree to Pay the Cost of Their Child’s Law Degree, Maybe the Government Will?

Foster Garvey PC on

Earlier this week, United States Tax Court Judge Richard T. Morrison ruled, in the case of Emmanuel A. Santos v. Commissioner, T.C. Memo 2016-100 (May 17, 2016), that the government will not pay the cost of a taxpayer...more

Pierce Atwood LLP

Massachusetts Appellate Tax Board Rejects Utility Loss Carryback

Pierce Atwood LLP on

Massachusetts Electric Company v. Commissioner of Revenue - Appellate Tax Board Docket No. C310170 (February 24, 2016) - The Appellant, Massachusetts Electric Company (“MEC”), was a Massachusetts public utility...more

McNees Wallace & Nurick LLC

Pennsylvania’s NOL Cap Litigation Moving Forward

In a Corporate Net Income Tax (“CNI”) appeal filed by Nextel Communications of the Mid-Atlantic, Inc. (“Nextel”), the Commonwealth Court will consider whether Pennsylvania’s statutory cap on net operating loss (“NOL”)...more

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