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.
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.
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...
In Mukhi v. Commissioner of Internal Revenue, a collection due process case, the U.S. Tax Court considered multiple constitutional challenges to civil penalties...