On January 14, 2025, the Treasury Department and IRS issued final and proposed regulations on sourcing income from digital content and cloud transactions.
Why is Source Important?
While U.S. persons generally are...more
Section 897 of the Internal Revenue Code provides that gain or loss of a nonresident alien or foreign corporation from the disposition of a United States real property interest is subject to U.S. federal income tax. And,...more
The Treasury Department and Internal Revenue Service are proposing regulations that would make so-called basket contract transactions as listed transactions under section 6011(a) of the Internal Revenue Code....more
On June 17, 2024, the Treasury Department launched “a new regulatory initiative to close a major tax loophole exploited by large, complex partnerships.”[1] The loophole: partnership basis-shifting transactions....more
In a blog post on May 21, 2024, National Taxpayer Advocate Erin Collins called for the IRS to cease its systemic assessment of international information return penalties and for Congress to amend the Internal Revenue Code to...more
A recent Tax Court case illustrates the importance under current case law of thinking about the tax consequences of a potential verdict or settlement early on and attempting (if the facts allow) to establish a basis for...more
The Treasury Inspector General for Tax Administration (“TITGA”) recently has released a report on the status of efforts by the Internal Revenue Service (“IRS”) to develop the digital asset monitoring and compliance strategy...more
No gain or loss generally is recognized on a transfer of property to a partnership in exchange for an interest in that partnership for federal income tax purposes (note that “partnership” here includes a limited liability...more
In an “applicable asset acquisition,” the sale of the assets of a business may be subject to certain allocation and reporting requirements for federal income tax purposes. It’s essential for the seller and purchaser to be...more
The United States Virgin Islands (“USVI”) is an unincorporated territory of the United States.[1] But that doesn’t mean that they’re subject to exactly the same laws as in the United States—especially when it comes to taxes....more
Hey everybody! Welcome back to another for another edition of Texas Tax Roundup! Hope y’all had a happy Thanksgiving! We got some franchise tax apportionment, some sales and use tax in the oil and gas industry, and some...more
Are you U.S. citizen or resident? Have you ever just wanted to leave the whole U.S. federal tax system behind? Well, you can . . . try at least. But there’s a cost....more
Court Cases Sales and Use Tax Manufacturing Exemption Hegar v. Tex. Westmoreland Coal Co., Case 21-1007 (Tex. Sept. 30, 2022)—In this case, the Texas Supreme Court denied the Comptroller’s petition for review, leaving the...more
One of the more confusing areas of international tax law is determining when withholding is required.
Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more
Howdy folks, and welcome back to another action-packed edition of the Texas Tax Roundup! Let’s see what shocking developments in the realm of Texas tax that the month of August had in store!...more
10/5/2022
/ Administrative Law Judge (ALJ) ,
Exports ,
Franchise Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Sales Tax ,
State Taxes ,
Tax Liability ,
Tax Planning ,
Tax Returns
In 2021, the Texas Legislature made it easier for taxpayers to challenge tax assessments without first paying the disputed amounts of tax due. Prior to this change, pay-to-play was the only game in town. Under pay-to-play, a...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation -
AN EXPERIENCE UNLIKE ANY OTHER -
Find yourself on the cutting-edge of international tax law, with...more
8/31/2022
/ Continuing Legal Education ,
Cross-Border ,
Cryptocurrency ,
Enforcement ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
Multinationals ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Reform ,
Transfer Pricing ,
Webinars
Bailey v. Drexel Furniture Co., 259 U.S. 20 (1922) (a/k/a “Child Labor Tax Case”) - Summary: In the Child Tax Labor Case, the U.S. Supreme Court ruled that a purported “tax” was really a “penalty” and therefore an...more
One of the more complicated areas involving Texas sales and use tax is the taxation of various new construction and real property repair and remodeling services. Determining what’s taxed and what’s not requires delving...more
Things have been heating up this summer. Let’s see what’s been cooking with the Texas Comptroller’s office....more
On June 7, 2022, a bill was introduced in the U.S. Senate that would provide greater clarity regarding the taxation and regulation of digital assets. Here are some of highlights....more
Howdy folks, and welcome back to another captivating installment of Texas Tax Roundup, where we gab about all things Texas taxes. Nothing court-side this month, just a bunch at the administrative level. Still, it’s...more
Howdy y’all! Has it been a month already? We’ve got another action-packed month of Comptroller-related news. Here we go! Court Cases Courts of Appeals Hegar v. Black, Mann, and Graham, L.L.P., No. 03-20-00391-CV (Tex....more
Huh whuh? . . . Well . . . Well, howdy! Nice, erm, um well . . . Nice to see ya’ll again at or near this nebulous home home on the range of Texas taxability! Welcome back to another tax-packed installment of all things Texas...more
Foreign Gifts and IRS Reporting - U.S. persons who receive gifts or bequests from foreign persons beware—these gifts or bequests may need to be reported to the Internal Revenue Service (“IRS”). The consequences for failing...more