In its 2019 Spring Term, the Supreme Court published five decisions regarding tax matters, three of which limit states’ taxing authority. In a February decision, Dawson v. Steager, the Court held that a state cannot tax a federal retiree’s pension benefits while declining to tax a similarly situated state retiree. The March decision in
In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and tax associate Stefan Herlitz analyze the costly risks that loom if retailers collect too much sales tax including private class action lawsuits seeking refunds of over-collected sales tax.
The authors explain that the trend of
On March 21, 2019, the IRS announced it is temporarily suspending two revenue rulings addressing tax-free spinoffs. The suspended rulings had arguably required the distributing corporation and the spun-off corporation to each independently generate current revenue. This development is welcome news for life sciences, technology, and other research and development (R&D)-focused business organizations that did
As first published in the March 22nd issue of Tax Journal, London tax partner, Andrew Howard, examines the Court of Justice of the European Union’s (the CJEU) landmark ruling on withholding tax and abuse of rights in the Danish conduit cases. In the Danish conduit cases, the CJEU has found that the establishment of holding