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Results: 1-10 of 5,251

Deductibility of settlement payments: US First Circuit rejects the IRS’s interpretation of Talley and section 162(f)

  • Mayer Brown LLP
  • -
  • USA
  • -
  • August 19 2014

In Fresenius Medical Care Holdings, the US Court of Appeals for the First Circuit held that taxpayers can meet their burden of proving that a

Unravelling the fiduciary tangle

  • Bartier Perry
  • -
  • Australia
  • -
  • August 19 2014

The recent High Court case of Howard v Commissioner of Taxation provides a useful summary of aspects of the law relating to fiduciary duties and

First Circuit issues important, favorable ruling concerning the tax deductibility of FCA settlements

  • Sidley Austin LLP
  • -
  • USA
  • -
  • August 19 2014

Last week, in Fresenius Medical Care Holdings, Inc. v. United States, No. 13-2144, __ F. 3d __ (1st Cir. Aug. 13, 2014), the Court of Appeals for the

The Supreme Court of Appeal admonishes the South African Revenue Service

  • ENSafrica
  • -
  • South Africa
  • -
  • August 19 2014

Under the provisions of the Tax Administration Act, the Commissioner: South African Revenue Service ('SARS') is entitled to request that a taxpayer

Maria Elisa Turullols - the taxation of payments under interim relief orders

  • Burges Salmon LLP
  • -
  • United Kingdom
  • -
  • August 18 2014

In Maria Elisa Turullols v HMRC (TC03795), the First Tier Tribunal ("FTT") held that a payment made to a "whistle blower" pursuant to an order for

Bankruptcy court lacks subject matter jurisdiction to determine tax refund claim requested by post-confirmation liquidating trustee

  • Greenberg Traurig LLP
  • -
  • USA
  • -
  • August 18 2014

A bankruptcy court lacks subject matter jurisdiction to determine a tax refund claim under Section 505(a)(2)(B) of the Bankruptcy Code where the

The tax regime of distributed income in case of share repurchase is declared unconstitutional

  • Baker & McKenzie
  • -
  • France
  • -
  • August 15 2014

In a decision dated June 20, 2014, No. 2014-404 QPC, the French Constitutional Court, seized by a priority preliminary rulings on the issue of

To appreciate a change of destination of an immovable property, the company's intention should be assessed in the light of all the circumstances at stake and not only in the light of the existence of an express decision taken by its statutory bodies

  • Baker & McKenzie
  • -
  • France
  • -
  • August 15 2014

A company - whose corporate purposes consists of (i) purchasing and reselling with the possibility to elect for the real estate dealers tax regime

A new loophole in the tax group regime: CJEU, Jun. 12, 2014, case C-4013

  • Baker & McKenzie
  • -
  • European Union
  • -
  • August 15 2014

In its June 12, 2014 decision, the Court of Justice of the European Union (case 4013) ruled on the issue of the extent to which the ban on forming a

Abusive merger: the French Administrative Supreme Court's decision on April 11, 2014, 9th and 10th subsect., no. 352999, Min. v. SARL Garnier Choiseul Holding

  • Baker & McKenzie
  • -
  • France
  • -
  • August 15 2014

In an April 11, 2014 decision, the French Administrative Supreme Court completed its reversals of cases favorable to taxpayers, handed down in recent