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UK: employment update - May 2013

Clifford Chance LLP
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United Kingdom
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May 23 2013

This edition of Employment Update looks at two cases which examine the necessary ingredients for an employer to be contractually bound by a promise to

Tax Court finds indirect prohibited transaction in IRA

Sutherland Asbill & Brennan LLP
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USA
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May 22 2013

In Peek v. Commissioner (May 9, 2013), the U.S. Tax Court ruled that two taxpayers had engaged in an indirect "prohibited transaction" with their

VAT - update on ECJ cases

Matheson
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European Union, Ireland
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May 22 2013

In our previous update, we analysed two Advocate General opinions of the ECJ in the context of Irish legislative provisions which (i) allow an

N.Y. ALJ holds taxpayer’s motives for acquiring stock and how stock is used irrelevant in determining investment capital

McDermott Will & Emery
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USA
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May 22 2013

A New York administrative law judge recently held in Matter of C.V. Starr & Co., Inc. that income received by a taxpayer from its ownership of common

UK utilities windfall tax is eligible for U.S. foreign tax credit

Bryan Cave LLP
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United Kingdom
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May 22 2013

The United States Supreme Court, on May 20, 2013, held, in PPL Corp. v. Commissioner, that the United Kingdom's one-time "windfall tax" imposed on U

The Gwartz decision: the GAAR is not a filler

Dentons
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Canada
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May 22 2013

In Brianne Gwartz v. The Queen, 2013 TCC 86, the Crown attempted to utilize the GAAR to recharacterize as dividends certain capital gains which had

Massachusetts District Court explores the United States’ burden of proof argument on deductions of government settlements

Mayer Brown LLP
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USA
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May 21 2013

On May 9, 2013, the US District Court of Massachusetts issued a Memorandum and Order in Fresenius Medical Care Holding, Inc. v. United States

Tax Court of Canada issues a comprehensive ruling on privilege issues and the appropriate exercise of remedies to address deficient lists of documents

Dentons
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Canada
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May 21 2013

In a recent Tax Court of Canada ruling on a motion heard in Imperial Tobacco Canada Limited v. The Queen, 2013 TCC 144 the Court considered a motion

Supreme Court settles Fifth Amendment required records issue in context of offshore bank accounts

Baker & Hostetler LLP
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USA
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May 21 2013

On May 13, 2013, the Supreme Court denied a taxpayer's petition for certiorari regarding the Seventh Circuit's August 27, 2012, decision applying the

Government runs its record to 4-0 in compelling production of records of offshore bank accounts

Baker & Hostetler LLP
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USA
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May 21 2013

On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit joined "the three of our sister circuits that have considered the same issue

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Search results

UK: employment update - May 2013

Tax Court finds indirect prohibited transaction in IRA

VAT - update on ECJ cases

N.Y. ALJ holds taxpayer’s motives for acquiring stock and how stock is used irrelevant in determining investment capital

UK utilities windfall tax is eligible for U.S. foreign tax credit

The Gwartz decision: the GAAR is not a filler

Massachusetts District Court explores the United States’ burden of proof argument on deductions of government settlements

Tax Court of Canada issues a comprehensive ruling on privilege issues and the appropriate exercise of remedies to address deficient lists of documents

Supreme Court settles Fifth Amendment required records issue in context of offshore bank accounts

Government runs its record to 4-0 in compelling production of records of offshore bank accounts

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