4 Key Takeaways | NY Sales Tax on Cloud-Based Document Management Services
Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
One of the first rules of business is that you don’t leave money on the table. That adage is equally important in tax matters. Taxpayers can leave behind funds by failing to follow the rules. The importance of compliance with...more
The California State Legislature overturned Microsoft’s recent win at the Office of Tax Appeals, which held that the gross amount of dividends received from foreign affiliates outside its water’s-edge group should be included...more
Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more
The California Office of Tax Appeals (OTA) denied a request for rehearing of a July 2023 OTA opinion favorable to Microsoft Corp. that could have wide-ranging impacts for a water's edge filer in California, particularly one...more
The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more
Microsoft's recent California Office of Tax Appeals win results in the opportunity for significant California corporate tax refunds for taxpayers with dividends from foreign affiliates....more
When we previously wrote about the Joint Committee on Taxation’s (JCT) process for reviewing refund claims granted by the Internal Revenue Service (IRS), we explained that the IRS generally must submit proposed refunds in...more
Last week, nine Cook County school districts and Calumet City filed an amicus curiae (“friend of the court”) brief in the Seventh Circuit Court of Appeals in support of rehearing in the case A.F. Moore & Associates Inc. v....more
Buckingham Tax Attorneys Steve Dimengo and Rich Fry recently obtained a favorable ruling from the 9th District Court of Appeals for their client in Karvo Paving Co. v. Testa, 2019-Ohio-3974. This victory enables highway and...more
Recently, the Ohio Board of Tax Appeals (BTA) denied a taxpayer’s sales tax refund in part because it could not consider the taxpayer’s improperly submitted evidence. In Environmental Quality Management Inc. v. McClain, BTA...more
Pennsylvania taxpayers should be aware of the recent decision by the Pennsylvania Supreme Court in Mission Funding Alpha v. Commonwealth, in which the court held that a refund claim is timely only if it is filed within three...more
May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more
ALJ holds that Insurance Payments to Captive Insurance Company Are not Deductible - In Matter of Stewart’s Shops Corp., DTA No. 825745 (N.Y.S. Div. of Tax App., Mar. 10, 2016), a New York State Administrative Law Judge...more
On September 19, 2014, the Pennsylvania Commonwealth Court in Fish, Hrabrick and Briskin v. Township of Lower Merion, No. 1940 C.D. 2013, held that lease receipts are not taxable under local business privilege tax ordinances....more