Taxation
Illinois Tool Works Inc. v. Commissioner
Tax Court Holds in Favor of Taxpayer on Loan Between Foreign Subsidiaries.
Taxation
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Preemption
Self-Insurance Institute of America, Inc. v. Snyder
Sixth Circuit Holds that ERISA Does Not Preempt Michigan Medicaid Tax Law.
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Taxation
Olive v. Commissioner
Ninth Circuit Holds Medical Marijuana Dispensary Ineligible for Federal Tax Deductions.
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Taxation
Comptroller of the Treasury of Maryland v. Wynne
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Taxation
Importing a Trade or Business Limitation into § 2036: Toward a Regulatory Solution to FLP-Driven Transfer Tax Avoidance
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Taxation
Taxing Partnership Profits Interests: The Carried Interest Problem
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Administrative Law
Intermountain Insurance Service of Vail, LLC v. Commissioner
Federal Tax Court Holds Pre-Chevron Judicial Construction of Statute Precludes Subsequent Agency Interpretation if Prior Construction Was Premised on Legislative History.
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Commerce Clause
Department of Revenue of Kentucky v. Davis
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Corporate Law
Taxing Private Equity Carried Interest Using an Incentive Stock Option Analogy
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Property
Equal Opportunity and Inheritance Taxation
Equality of opportunity is understood to be one of the bedrock principles supporting the taxation of inheritance. The familiar idea is that inherited wealth offers an unjustified head start for some individuals…