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Sarah P. Hogarth advises clients on complex litigation matters with a focus on appeals and major motions practice. She has briefed dozens of appellate matters and dispositive trial-court motions covering a wide variety of substantive areas. Her experience includes matters involving federal practice and jurisdiction, constitutional law, preemption, health care, patents, copyrights, trademarks, trade dress, false advertising, trade secrets, commercial contracts, the False Claims Act, the Federal Arbitration Act, administrative law, insurance, and taxation.

Nebraska District Court Holds That GIL 24-19-1 is Not Afforded Deference


By , and on Jun 24, 2021
Posted In Federal Tax, Income Tax, Local Tax, Nationwide Importance, Tax Base

Last week, the Lancaster County District Court granted the state’s motion to dismiss in COST v. Nebraska Department of Revenue. COST brought this declaratory judgment action to invalidate GIL 24-19-1, in which the department determined that earnings deemed repatriated under IRC § 965 are not eligible for the state’s dividends-received deduction and are thus subject...

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