• Posts by Kenneth S. Levinson
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    Ken focuses on worldwide tax planning, transaction structuring and a number of tax issues related to mergers and acquisitions, IP licensing, employee relocation, and international franchising. He has extensive experience ...

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What? Another Supreme Court Tax Case? Yup, but you really ought to watch THIS one…

The U.S. Supreme Court will hear another tax case in the upcoming 2023-2024 session. This one, Moore v. United States, is a doozy...

Professor Moriarty Is Going to Make an Appearance at the U.S. Supreme Court

The Supreme Court accepted United States v. Bittner for certiorari on June 21, 2021, and the case will be argued on Tuesday, November 02, 2022.

As Sherlock Holmes Would Say, “The Game’s Afoot”: A Possible SCOTUS Tax Case?

If you are into Foreign Bank Account Reports (FBARs), your concern about penalties for failing to comply with those FinCEN 114 reporting rules just took an exciting, and perhaps fearsome, turn.

Tax Issues in the Use or Disposition of International Intangibles: The Good, the Bad, and the Ugly (Part II)

This week, we turn to international transactions that involve licenses or the provision or performance of e-commerce services.

Tax Issues in the Use or Disposition of International Intangibles: The Good, the Bad, and the Ugly (Part I)
The transfer or use of intangibles generally is a complicated area of taxation, and one that continues to evolve.
Captives, NRRA and Nonadmitted Insurance Premium Taxes – A Primer (Part II)
Last week, we reviewed the basics about captive insurance companies, nonadmitted insurance and the essence of the federal legislation known as the NRRA. This week, we examine what the states did to implement NRRA and how that affected, or may affect, insurance premiums paid to out-of-state captives.
Captives, NRRA and Nonadmitted Insurance Premium Taxes – A Primer (Part I)
We are seeing increased focus by state tax departments on nonadmitted insurance premium reporting, tax payments owed and auditing of captive insurance companies. This article is Part I of our primer on the application of the nonadmitted premium tax rules to purchases of insurance from out-of-state captives.
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