Trump v. IRS: A $10 Billion Claim for Unauthorized Disclosure of Tax Returns On January 29,…
I. Introduction: The Problem of Dual Tax Regimes The proper tax characterization of a loan agreement…
The Demise of the “Near-Sole Shareholder” Doctrine and the Emerging Problem of Sham Multi-Member Structures …
In dubio pro tributario (Lat. “when in doubt, in favor of the taxpayer”; Ger. Zweifel zugunsten…
I. Introduction Many entrepreneurs regard the principle of in dubio pro tributario as a trump card…
I. Introduction: The Tension Between Fiscal Efficiency and Financial Privacy Few questions in modern tax law…
Poland built an algorithm to catch tax cheats. It works—except when it doesn’t. On a Monday…
For nearly five years, the tax authority pursued fruitless enforcement proceedings against a company’s assets —…
Polish Courts and the Expanding Doctrine of Manifest Unconstitutionality How the Kielce Administrative Court’s 2023 Ruling…
When the Fisc Buys Time The statute of limitations on tax obligations constitutes one of the…
Tax audits and regulatory inspections of business operations constitute among the most burdensome forms of state…
I. Introduction The Value Added Tax (VAT) stands as the preeminent instrument of indirect taxation across…
Running separate businesses by spouses under a statutory community property regime is a common phenomenon in…
Preferential Tax Treatment Under Polish Law and the Approaching 2026 Legislative Reform I. Introduction Equity-based and…
Confidentiality Clauses and the Right to Legal Counsel: The Boundaries That Non-Disclosure Agreements Cannot Cross In…
Genesis allocation—the initial distribution of tokens created contemporaneously with the establishment of a new blockchain network—presents…
Theoretical Foundations, Comparative Frameworks, and the Regulatory Challenges of Decentralized Finance Cryptocurrency taxation encompasses the corpus…
I. Introduction The participation exemption—known variously as Schachtelprivileg in German jurisprudence, exonération des dividendes in French…
In December 2025, the Regional Administrative Court in Olsztyn rendered a judgment that may significantly reshape…
The Look-Through Approach in Polish Case Law I. Introduction: The Beneficial Owner Clause and Preferential WHT…
Tax authorities may not uncritically accept evidentiary materials transmitted by prosecutorial offices or intelligence services. Where…
The tax audit protocol (protokół kontroli podatkowej) occupies a position of singular importance within the Polish…
The utilization of trademark licensing arrangements between affiliated entities represents a prevalent tax planning mechanism across…
Prejudgment security over taxpayer assets presents an instrument of dual character: on one hand, it safeguards…
When the Tax Authority Comes Knocking Asset seizure by the tax office represents the ultimate coercive…
The principle of free evaluation of evidence constitutes the cornerstone of fact-finding in tax proceedings, establishing…
The principles governing the gathering of evidentiary material constitute the foundation of fair and lawful tax…
Extraordinary Remedies Under Polish Tax Procedure The revocation or modification of a final tax decision constitutes…
This article examines the increasingly prevalent practice of utilizing Article 176 of the Polish Commercial Companies…
Official Documents, Counter-Evidence, and the Limits of Administrative Discretion This Article examines a landmark decision by…
