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Holding Company Gets Factored Out of Parent's Colorado Combined Return
  • Sutherland Asbill & Brennan LLP
  • USA
  • February 3 2016

On January 20, a Denver trial court ruled that Agilent Technologies World Trade, Inc. (World Trade), a holding company with no property or payroll of

Open for Nonbusiness: Oregon Tax Court Holds Insurance Company's Gain Was Nonbusiness Income
  • Sutherland Asbill & Brennan LLP
  • USA
  • February 1 2016

The Magistrate Division of the Oregon Tax Court held that an insurance company's gain from the sale of a subsidiary and income from a holding

New Partnership Audit Rules Impact Both Existing and New Partnership and LLC Operating Agreements
  • McDermott Will & Emery
  • USA
  • January 29 2016

On November 2, 2015, President Barack Obama signed the Bipartisan Budget Act of 2015 (the Act) into law, instituting for tax years commencing after

Desperately Seeking Substance: Maryland Circuit Court Upholds Nexus Based on Intangible Holding Company's Lack of Economic Substance
  • Sutherland Asbill & Brennan LLP
  • USA
  • January 26 2016

The Maryland Circuit Court held that an intangible holding company lacked economic substance and therefore was subject to Maryland corporate income

NYS Tax Department Relaxes Investment Income Identification Rules
  • McDermott Will & Emery
  • USA
  • January 11 2016

The New York State Department of Taxation and Finance has announced that it would extend the time for certain taxpayers to identify stocks as being

Corporate Crime & Investigations Update - 11 January 2016
  • Addleshaw Goddard LLP
  • Ukraine, United Kingdom, USA
  • January 11 2016

Southwark Crown Court ordered Smith and Ouzman Ltd. to pay a total of approximately £2.2 million in relation to bribes paid to public officials for

2015 year-end tax update
  • Cozen O'Connor
  • USA
  • December 31 2015

“Make America Great Again!” Sounds like a terrific idea, even for those (few?) of us who think America is already great and who are somewhat

What to do with a Delaware unclaimed property audit document request? Pending litigation may provide an answer
  • Reed Smith LLP
  • USA
  • December 15 2015

If you have received a request for information in connection with a Delaware unclaimed property audit that appears to be excessively broad and you

A steep slope Vermont Supreme Court finds AIG not unitary with a ski resort based on a clear and cogent evidence burden of proof
  • McDermott Will & Emery
  • USA
  • November 30 2015

In the first Vermont Supreme Court decision addressing combined unitary reporting since Vermont’s combined reporting regime became effective in 2006

HMRC responds to landmark case on UK tax treatment of Delaware LLCs
  • Latham & Watkins LLP
  • United Kingdom, USA
  • November 19 2015

Business as usual for UK taxpayers following Supreme Court decision in Anson v HMRC? HM Revenue and Customs (HMRC) has published its response to the