Waste Not, Want Not: The High Court Finds That HMRC Breached Legitimate Expectation On Landfill Tax

By | Focus on Regulation | June 30, 2016

The High Court, in the recent case of R (Biffa Waste Management Services Ltd) v the Commissioners for HMRC [2016] EWHC 1444 (Admin), has provided much needed clarification on taxpayers’ entitlement to rely upon rulings by HMRC where the ruling is general in nature but framed to apply only to specific transactions.

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Federal Court Finds Delaware’s Unclaimed Property Enforcement “Shocks the Conscience”

Federal Court Finds Delaware’s Unclaimed Property Enforcement “Shocks the Conscience”

On June 28, 2016, the much-anticipated memorandum opinion of the US District Court for the District of Delaware in Temple-Inland, Inc. v. Cook et al., No. 14-654-GMS was released on the parties’ cross-motions for summary judgment, finding Delaware’s extrapolation methodology and audit techniques collectively violate substantive due process. 

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The Death of Prince Rogers Nelson – an Estate Tax Controversy Likely to Follow

By | Larry's Tax Law | June 29, 2016
The Death of Prince Rogers Nelson – an Estate Tax Controversy Likely to Follow

Many of our readers have asked me about the likely controversy that will ensue following the death of Prince. In fact, two readers feel, since I have been reporting about some of the controversy surrounding the Estate of Michael Jackson, that I must write about Prince’s estate and the expected controversy surrounding it. So, here we go!

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Italy’s Supreme Court Denies Treaty Benefits to UK Holding Company Under Beneficial Ownership Clause of UK-Italy Treaty

Italy’s Supreme Court Denies Treaty Benefits to UK Holding Company Under Beneficial Ownership Clause of UK-Italy Treaty

The Italian Supreme Court with its ruling n. 10792 of May 25, 2016 held that the 5 percent reduced dividend withholding tax provided for under article 10 of UK-Italy Tax Treaty does not apply, when the company that receives the dividends does not prove that it is the “beneficial owner” of the dividend as required under the relevant provision of the applicable tax treaty.

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