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When It Sounds Too Good To Be True, It Usually Is

Client Alert | less than 1 min read | 02.14.06

Many of us were surprised in 2000 when the Court of Federal Claims found that state income taxes paid by the individual owner of a Subchapter S corporation were allowable state income costs of the corporation on contracts performed by the corporation. It comes as no surprise that the Court of Appeals for the Federal Circuit has reversed in Information Systems & Networks Corp. v. U.S. (Feb. 6, 2006), holding that, when state law follows federal law and imposes income taxes on the owners of Subchapter S corporations but not on the corporations themselves, the corporations are exempt from taxation and the tax paid by the individual owner is not an allowable cost of the corporation.

Insights

Client Alert | 7 min read | 08.12.26

Developments in Canadian Investment Treaty Practice: New FIPA Between Canada and UAE in Force

Of particular interest for investors with interests in Canada or the UAE, for counsel advising on treaty coverage, dispute strategy, or treaty design, the Canada-UAE FIPA is essential reading and the clearest evidence yet of where Canada's investment treaty practice stands over 30 years after NAFTA came into force....