| 24-332 |
International Business Machines Corporation & Combined Affiliates v. New York Tax Appeals Tribunal, et al. |
New York |
2024-09-24 |
Denied |
Amici (1) |
commerce-clause double-taxation foreign-commerce interstate-commerce state-taxation tax-nexus |
May a state impose a "heads I win, tails you lose" regime that taxes either side of an interstate or foreign transaction, depending on which side has … |
| 20-1300 |
Emilio Torres Luque, et al. v. Commissioner of Internal Revenue |
Ninth Circuit |
2021-03-19 |
Denied |
Response Waived |
cross-border-residency double-taxation international-tax-law ninth-circuit reciprocity residency revenue-procedure supremacy-clause tax-treaty treaty-interpretation |
This is a case of first impression. There are no similar cases that either party or the Court's own research could find. The Supremacy Clause of Artic… |
| 19-755 |
Robert C. Steiner, et ux. v. Utah State Tax Commission |
Utah |
2019-12-12 |
Denied |
Amici (3)Response Waived |
dormant-commerce-clause double-taxation equal-protection foreign-commerce interstate-taxation state-residency state-tax-credits state-taxation tax-credit tax-credits |
Utah's tax code extends a credit for income taxes paid to other States but does not extend a similar credit for income taxes paid to foreign countries… |
| 18-1569 |
Richard Chamberlain, et ux. v. New York State Department of Taxation and Finance, et al. |
New York |
2019-06-24 |
Denied |
|
comptroller-of-treasury-of-maryland-v-wynne constitutional-challenge domicile dormant-commerce-clause double-taxation intangible-income interstate-taxation state-taxation tax-credits tax-jurisdiction tax-residency wynne-precedent |
Whether a state tax scheme that taxes the intangible income of individuals who are domiciled in the State and certain individuals not domiciled in the… |
| 18-1485 |
Michael Kansler, et ux. v. Mississippi Department of Revenue |
Mississippi |
2019-05-29 |
Denied |
Response Waived |
commerce-clause double-taxation due-process income-tax internal-consistency internal-consistency-test interstate-commerce residency state-tax-law state-taxation statute-of-limitations tax-statute-of-limitations |
1. Is Mississippi's income tax refund statute of limitation immune per se from Commerce Clause scrutiny under Complete Auto Transit, Inc. v. Brady, 43… |