Tax Residency in International Law: Doctrine, Mechanisms, and Contemporary Challenges Tax residency (Ger. steuerliche Ansässigkeit; Fr.…
A Dual-Jurisdiction Analysis Under Polish Domestic Law and the 1974 Poland–United States Tax Convention Robert Nogacki…
Introduction: The Enduring Significance of Source-State Taxation Withholding tax—the mechanism by which a source state levies…
Introduction: The Capital Increase as a Taxable Event A share capital increase—the corporate operation by which…
Introduction The holding company—broadly defined as an entity whose principal purpose consists in the acquisition, retention,…
The Holding Exemption and Probatio Diabolica When the Tax Authority Ignores the Supreme Court and Demands…
An Essay in the Philosophy of Science THE ORIGIN OF LIFE: AN UNSOLVED PROBLEM There…
The taxation of lending transactions (Pol. opodatkowanie pożyczek; Ger. Darlehensbesteuerung; Fr. taxation des prêts) encompasses the body of rules governing the…
When a Failed Transaction Does Not Constitute Taxable Income Does a failed conversion of a loan…
When a Certificate of Residence and a Statutory Declaration Are Not Enough A Polish company distributes…
May the tax authority deny the dividend withholding tax exemption to a company that formally satisfies…
How Bank of America, JPMorgan and Deutsche Bank Financed Sex Trafficking Bank of America has settled…
For years, we treated fake online reviews the way most people treat termites — as…
Three courtrooms, one corporation, and the legal reckoning that could reshape the internet By Robert Nogacki…
DEATH, DATA, AND THE PRESUMPTION OF INNOCENCE Robert Nogacki | Skarbiec Law Firm | Warsaw It…
What Anthropic’s lawsuit against the Pentagon reveals about the coming age of autonomous weapons At 12:47…
A Warsaw court has finally convicted the architects of one of Poland’s most audacious financial crimes.…
I. Stolen Faces, Synthetic Voices: Before the Law Catches Up In July of 2024, a senior…
The Ghost in the Machine Has Retained Counsel By Robert Nogacki In 1961, Stanisław Lem—a doctor’s…
INTRODUCTION The taxation of gratuitous transfers—whether effected through testamentary succession, inter vivos gift, or analogous mechanisms…
Consensus, Convalidation, and the Limits of Retroactive Unwinding Under Polish Gift Tax Law Monetary gifts between…
How Hidden Linguistic Patterns in Contracts Can Manipulate AI Contractual steganography is a new category of…
Trump v. IRS: A $10 Billion Claim for Unauthorized Disclosure of Tax Returns On January 29,…
Texas Sues Lorex for Misleading Consumers—and Exposes the Hidden Surveillance Architecture Inside Home Security Cameras …
Learning Resources v. Trump and the question the Framers thought they’d settled in 1787 On February…
Somewhere in the Saarland—that sliver of Germany wedged between France and Luxembourg, a region better…
DocuSign and the Limits of Electronic Execution: Form Requirements, Evidentiary Presumptions, and the Legal Fragility of…
Personal income tax (Polish: podatek dochodowy od osób fizycznych, PIT; German: Einkommensteuer; French: impôt sur le…
Civil transaction tax (Polish: podatek od czynności cywilnoprawnych; German: Rechtsverkehrsteuer, Grunderwerbsteuer; French: droits d’enregistrement; also rendered…
I. Introduction: The Problem of Dual Tax Regimes The proper tax characterization of a loan agreement…
