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Paul H. Frankel

Senior Counsel
New York, (212) 468-8034
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ABB C-E Nuclear Power, Inc.
The Missouri Supreme Court ruled that the gain recognized by a corporation from the sale of a subsidiary in an IRC Section 338(h)(10) transaction constituted non-business income for Missouri tax purposes.
Sherwin-Williams Co.
The Supreme Judicial Court of Massachusetts held that companies may legally reorganize themselves and, as long as the reorganization has economic substance, it must be respected for tax purposes even if the new structure also provides tax benefits.
State Tax Settlement for Major Chemical Company.
Favorably settled a major state tax case in a Midwestern state for a national chemical company, resulting in complete elimination of the asserted deficiency.
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