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Articles by Marc M. Levey
United States: Section 7508A(d) suspends timeframe for filing tax court petitions for certain disaster declarations
On 2 April 2024, the US Tax Court held in Abdo v. Commissioner, 162 T.C. No. 7 (2024), held that the COVID-19 pandemic entitled the taxpayers to an additional 60 days to file their Tax Court petition to redetermine a deficiency. In a court reviewed opinion, the Tax Court had its first opportunity to rule on section 7508A(d), which suspends the running of the period within which a Tax Court petition must be filed due to the declaration of a national disaster.
Global Legal Guide for Luxury & Fashion Companies
The luxury and fashion industry has grown rapidly in recent years, driven by the rising worldwide demand of the image-conscious, growing middle classes in emerging markets, and the incredible advancement and evolution in online retail sales and marketing.
Global Legal Guide for Luxury & Fashion Companies
The luxury and fashion industry has grown rapidly in recent years, driven by the rising worldwide demand of the image-conscious, growing middle classes in emerging markets, and the incredible advancement and evolution in online retail sales and marketing.
United States: Third Circuit holds Tax Court's 90-day petition deadline is not jurisdictional
In brief In Culp v. Commissioner, the Third Circuit recently held that section 6213(a)'s 90-day period for filing a Tax Court petition for redetermination of a deficiency is not jurisdictional and is subject to equitable tolling. Relaxing strict compliance with the often draconian filing rule would allow taxpayers to have their day in court even if they fail to meet the 90-day deadline.
Transfer Pricing and Environmental Taxation: Carbon Credits Original
By the end of 2021, over 80 countries representing almost 75% of global emissions announced commitments to achieve net zero emissions. These “commitments” essentially translate into decarbonization rules or legislation. Following the Paris Agreement, countries party to the Paris Agreement put climate plans in place to cut their Green House Gas (GHG) emissions and set Nationally Determined Contributions (NDCs) that serve to measure progression towards reducing their GHG emissions.
OECD guidance on transfer pricing implications of COVID-19
On 18 December 2020, the OECD published Guidance on the transfer pricing implications of the COVID-19 pandemic (OECD Guidance) providing guidance to taxpayers when applying the arm's length principle and applying the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (OECD TPG) for periods impacted by the COVID-19 pandemic.
Marc Levey
On 18 December 2020, the OECD published Guidance on the transfer pricing implications of the COVID-19 pandemic (“OECD Guidance”) providing guidance to taxpayers when applying the arm’s length principle and applying the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (“OECD TPG”) for periods impacted by the COVID-19 pandemic.
United States: Final FDII Rules
Baker McKenzie's North America Tax Practice Group has prepared a Client Alert on the final regulations regarding foreign-derived intangible income (FDII) deductions under section 250 of the Code. The final regulations provide helpful and taxpayer-favorable guidance on relaxed documentation rules for establishing that the “foreign use” and foreign person requirements (for sales) and non-U.S. location requirement (for services) are satisfied.
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