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POPULAR ARTICLES ON: Tax from United States
An Analysis Of Pepsi's Tax Case In Australia: A Look At 'Embedded Royalties' And Diverted Profits Tax
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In this article, we explore the landmark decision in Pepsi Inc v Commissioner of Taxation [2023] FCA 1490 and its implications for the characterisation of royalties for multinational enterprises.
Massachusetts Income Tax Case Impacts Nonresident Stock Sales
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Phil outlines the Massachusetts Appellate Tax Board's decision in Welch v. Commissioner of Revenue and discusses how it could affect the taxation of income earned by nonresidents of Massachusetts.
The Symbiotic Relationship Between Tax Attorneys And Accountants
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It is not uncommon for a potential new client or even a new referral source to ask, "why would someone need to hire a tax attorney when they already have an ac­countant?" In many instances...
Tax Court Rejects Constitutional Challenges To International Information Return Penalties
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In Mukhi v. Commissioner of Internal Revenue, a collection due process case, the U.S. Tax Court considered multiple constitutional challenges to civil penalties...
Federal Income Taxation Of Intellectual Property Development And Cost Recovery
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Intellectual property ("IP") development can cost millions of dollars so cost recovery timing can be financially material.
Controlling The Sales Tax Function: A Human And Digital Partnership
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Following the 2018 Wayfair decision, many sellers are required to collect sales tax from their customers in more U.S. jurisdictions.
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