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No alternative to nexus: parent's royalty addback does not eliminate licensing subsidiary's New Jersey filing obligation
  • Sutherland Asbill & Brennan LLP
  • USA
  • August 27 2015

The New Jersey Tax Court ruled that the Division of Taxation ("Division") properly required a foreign (non-New Jersey domesticated) corporation to

Tax Court invalidates cost sharing regulation on stock-based compensation. Now what?
  • DLA Piper LLP
  • USA
  • August 11 2015

The Tax Court in Altera Corp. v. Commissioner, 145 T.C. No. 3 (2015) has determined that Treas. Reg. 1.482-7(d)(2) requiring related taxpayers to

Notice 2015-54 and certain contributions to partnerships with related foreign partners
  • Baker Botts LLP
  • USA
  • August 11 2015

In Notice 2015-54 (the "Notice"), released on August 6, 2015, the IRS announced that it intended to issue Treasury regulations under section 721(c

Waiver good-bye: the IRS targets management fee waiver arrangements
  • Mayer Brown LLP
  • USA
  • August 6 2015

The Obama administration has had a devil of a time getting Congress to pass carried interest legislation that would tax as ordinary income the

How to structure overseas independent contractors
  • K&L Gates
  • USA
  • July 28 2015

Independent contractor versus employee classification challenges come up increasingly as new work relationships emerge in the high-tech

How the recent Supreme Court term will affect business
  • Sullivan & Cromwell LLP
  • USA
  • July 23 2015

In Mach Mining, the Supreme Court considered whether and to what extent courts may review the Equal Employment Opportunity Commission’s attempt to

Hog wild: in Harley-Davidson, California Court of Appeal finds discrimination, affirms nexus
  • Sutherland Asbill & Brennan LLP
  • USA
  • July 21 2015

The California Court of Appeal held that California's disparate treatment of intrastate and interstate unitary businesses discriminated against

Homejoy’s shutdown, due to misclassification lawsuits, likely to propel tech start-ups to enhance their independent contractor compliance
  • Pepper Hamilton LLP
  • USA
  • July 17 2015

Earlier today, Carmel DeAmicis of Recode reported that Homejoy, the home cleaning start-up that uses independent contractors as their home cleaners

UK Supreme Court case of Anson v. HMRC 2015 UKSC 44
  • Proskauer Rose LLP
  • United Kingdom, USA
  • July 9 2015

The UK Supreme Court has handed down its judgment on the final appeal in the Anson case, in which it treated a taxpayer's interest in a Delaware LLC

Is it all now transparent? UK Supreme Court case on Delaware LLCs leaves open questions on entity classification for UK tax purposes
  • Shearman & Sterling LLP
  • United Kingdom, USA
  • July 6 2015

The UK Supreme Court delivered an unexpected final judgment on 1 July 2015 in the long-running case of Anson v Commissioners for Her Majesty's Revenue