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Blank Rome LLP

California Snags Former Resident for Tax Due on Stock Options

Blank Rome LLP on

Many employees receive stock options as compensation from their employers. When receiving this type of compensation, the state tax implications may not be at the forefront of the employees’ minds, especially where it may be...more

Allen Barron, Inc.

The Appeal of an IRS Audit is Based Upon the Audit's Examination File

Allen Barron, Inc. on

Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more

McDermott Will & Schulte

IRS Roundup January 13 – 17, 2025

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025. TAX CONTROVERSY-RELATED DEVELOPMENTS - January 15, 2025: The US...more

Skadden, Arps, Slate, Meagher & Flom LLP

Members of UK LLPs and Significant Influence: Commentary on HMRC v. BlueCrest Capital Management (UK) LLP

Skadden, Arps, Slate, Meagher & Flom LLP on

On January 17, 2025, the UK Court of Appeal (Court) released its decision on whether certain members of BlueCrest Capital Management (UK) LLP (BlueCrest) should be taxed as employees under the UK “salaried members” rules (the...more

Farrell Fritz, P.C.

Federal Tax Controversies and the Appeals Resolution Process

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The Taxpayer First Act (“TFA”), which was signed into law on July 1, 2019, makes the most significant changes to administrative procedures since the Internal Revenue Service Restructuring and Reform Act of 1998. In addition...more

Blank Rome LLP

Supreme Court of Arkansas Allows Corporation to Allocate Interest Expense Incurred to Fund Corporate Spin-off

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A recent Supreme Court of Arkansas decision has upheld a multistate corporation’s allocation to Arkansas of 100% of its interest expenses from borrowings to fund a spin-off. It also rejected as irrelevant the state’s attempt...more

Bradley Arant Boult Cummings LLP

Recent Rulings on “Family Limited Liability Entity” Election Create Traps for the Unwary

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Although every LLC, limited partnership or other pass-through entity doing business in Alabama, and even those simply organized under Alabama law, are subject to an annual business privilege tax (BPT), certain entities can...more

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