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U.S. Supreme Court Decision in Wayfair: Implications for Non-U.S. Businesses

USA - October 3 2018 On June 21, 2018, in South Dakota v. Wayfair ("Wayfair"),1 the United States Supreme Court (the "Court") reversed its decades-old ban on…

Walter R. Calvert

U.S. Supreme Court Decision in Wayfair: Implications for Non-U.S. Providers of U.S. Destination-Based Travel Solutions

USA - August 24 2018 On June 21, 2018, in South Dakota v. Wayfair ("Wayfair"),1 the United States Supreme Court (the "Court") reversed its decades-old ban on…

Walter R. Calvert

Tax Court Rejects Long-Standing IRS Approach to Taxing Gain and Loss on the Disposition of Partnership Interests

USA - July 25 2017 On July 13, 2017, the Tax Court, in a reviewed opinion of the court in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T…

Bryan H. Kelly

Disregarded Entity Partners Raise Gummy-Bears for Tax Audit Risk Management

USA - July 7 2017 In June, the U.S. Court of Appeals for the Ninth Circuit held that a single-member LLC (disregarded entity) holding an interest in an LLC (treated as…

Chaim Gordon

Effectively Connected Income and Penny Warrants

USA - June 21 2017 There is a case currently proceeding in the U.S. Tax Court (TELOS CLO 2006-1, Ltd. v. Commissioner, T.C., No. 6786-17, petitions filed 3/22/17) that…

Nicholas A. Jacobus