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WSJ Tax Articles

Interesting tax articles in today’s Wall Street Journal:

The year-end tax bill that cleared Congress promises long-awaited relief to taxpayers who exercised incentive stock options during the high-tech boom and became ensnared by the alternative minimum tax, even as their investments plummeted.

Europe’s highest court handed the U.K. government an important, if partial, victory in two cases concerning multinational companies such as British American Tobacco PLC and Sony Corp. The Luxembourg-based European Court of Justice is playing a critical role in deciding how multinational companies should be taxed across the borders of the European Union’s 25 member states. Tax lawyers said the two cases underline that the court is shifting more toward governments than taxpayers on tax issues.

In one ruling, the court rejected claims by Sony, along with Pirelli & C SpA, Essilor International SA and BMW AG, against the different tax treatment of dividends paid by U.K.-based companies to parent firms resident elsewhere. All four companies have subsidiaries in the U.K., while the parent firm is resident in another country.

In the other case, which involves BAT, the court insisted on some modifications to a U.K. rule that taxes dividends paid by nonresident subsidiaries of U.K. firms. Subsidiaries resident within the country aren’t subject to the same tax.

Congress has resurrected several popular tax breaks that expired last year. But because lawmakers took so long to act, the changes won’t appear on federal income-tax forms and instructions that millions of people will be receiving in coming weeks.


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