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ALJ finds responsible person liability for sales tax but declines to uphold fraud penalties
  • Morrison & Foerster LLP
  • USA
  • October 3 2015

A New York State Administrative Law Judge has upheld the imposition of personal liability for sales and use tax on an employee of a corporation, but

UK tax treatment of US LLC: HMRC’s practice following Anson
  • Dechert LLP
  • United Kingdom, USA
  • October 1 2015

We reported earlier this year on the UK Supreme Court's decision in HMRC v Anson, in which it was held that a UK taxpayer, Mr. Anson, was entitled to

Recent UK court decision on UK tax treatment of US LLCs
  • Morgan Lewis & Bockius LLP
  • United Kingdom, USA
  • September 30 2015

Delaware limited liability companies (LLCs) are regularly seen in many international corporate groups, including in advisory firms and as hedge and

Don't let your son incorporate the family business behind your back
  • Montgomery McCracken Walker & Rhoads LLP
  • USA
  • September 15 2015

Losses from a sole proprietorship will usually offset an individual's other income. But if the business is housed in a C corporation, its losses are

Tribunal upholds personal liability of LLC members for sales tax
  • Morrison & Foerster LLP
  • USA
  • September 2 2015

The New York State Tax Appeals Tribunal has affirmed the determination of an Administrative Law Judge that a member of a limited liability company

Employee incentives update August 2015 edition
  • Addleshaw Goddard LLP
  • United Kingdom, USA
  • August 31 2015

The Investment Association has changed the process it will follow for consultations on executive remuneration at UK listed companies.TAX First-tier

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