The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
It is estimated that over 80 percent of tax cases settle before a hearing is held. While this is generally a positive result for both taxpayers and Departments of Revenue, sometimes the fine print is overlooked—especially...more
In two recent decisions, Connecticut Tax Court Presiding Judge Matthew Budzik found that three facilities consisting of solar panels and related equipment were entitled to property tax exemptions pursuant to Connecticut...more
This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
Every year, the members of the Vermont Captive Insurance Association’s legislative committee and the Vermont Department of Financial Regulation (the “DFR”) work to improve Vermont’s captive insurance laws and regulations....more
With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more
In Bush v. Yarborough Oil & Gas, LP a decades-old tax foreclosure judgment did not affect a previously severed mineral interest not owned by the delinquent taxpayer. The mineral owners were neither named nor served in the...more
During the 2025 legislative session, the Georgia General Assembly passed several notable tax related bills including further decreasing the income tax rate and extending the time period for taxpayers to protest and appeal the...more
Income received by a multistate business is either “business income” or “non-business income.” Although this labeling appears innocuous, the distinction between these two categories of income matters greatly to taxpayers and...more
On February 5, 2025, the New Jersey Appellate Division released a decision in the matter of Christopher Gill v. Director (Docket No. A-3116-22), affirming the tax court’s holding that the state is not subject to a separate...more
On February 4, 2025, and by unanimous vote, the Brazilian Supreme Court’s (STF) Plenary confirmed that the non-levy of ICMS will only apply from the 2024 fiscal year, with the exception of administrative and judicial...more
Property owners who wish to challenge their tax assessment believing that their property is overvalued on the Oct. 1, 2024, Grand List only have a couple of weeks left to file a written appeal with the Board of Assessment...more
A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more
The New Jersey Tax Court has held that individual taxpayers were not required to include in their New Jersey gross income the undistributed earnings of controlled foreign corporations (“CFCs”) for purposes of the Gross Income...more
This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
In an unpublished opinion, the New Jersey Tax Court held that a web-based business solutions company was entitled to use market-based sourcing to source its 2011 and 2012 receipts even though market-based sourcing was not...more
The Georgia General Assembly passed several significant tax bills during the 2024 legislative session. Among them was the creation of a tax court in the judicial branch, a reduction of the individual and corporate income tax...more
Tax Court Modifies Rushmore Method for Hotel Valuation. The Maryland Tax Court recently modified the traditional Rushmore income approach used to determine the fair market value (FMV) of the real estate component of a hotel....more
Financed transactions can result in states asserting "heads I win, tails you lose" by taking the tax at the time of sale but not accepting pain when the installment sale is busted. When a sale of tangible personal property...more
Taxpayers and practitioners are often stymied by the lack of clarity or other information provided by state departments of revenue on tax issues. While the limited information can be understandable when a department does not...more
The challenges in establishing protection under Public Law 86-272 (“P.L. 86-272”) were on display in a recent decision of the Minnesota Tax Court. Uline, Inc. v. Commissioner of Revenue, Minn. Tax Court, No. 9435-R (June 23,...more
The Minnesota Tax Court held a catalog and internet-based distribution company exceeded the protections of Public Law 86-272 (PL 86-272) by providing non-sales personnel with information about competitors’ products and sales...more
Hasta La Vista N.Y.- Wealthy individuals continue to leave New York for tax friendlier jurisdictions. Be Prepared- Some of these taxpayers take a very methodical approach toward planning for their departure. They...more
Howdy folks, and welcome back to another edition of the Texas Tax Roundup, where we gab about all things Texas tax and perhaps even some things Texas tax adjacent. As ole T.S. once put it, “April is the cruelest...more
Hiya, folks and welcome back to a whole new edition (in a whole new year) of the Texas Tax Roundup! January started the year off with a blast! Let’s see what happened! Sales and Use Tax Governmental Exemption...more
We summarize here what we believe are the top 5 Alabama tax cases decided in the past year that would interest our CPA readers. Not surprisingly, almost all are Alabama Tax Tribunal rulings, so in those instances we deleted...more