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Tax Liability › Corporate Counsel › Internal Revenue Code (IRC)

Littler

Treasury Department Releases “Preliminary List” of “No Tax on Tips” Occupations

Littler on

The Treasury Department this week released a “preliminary list” of occupations that may be entitled to claim the “no tax on tips” deduction. As a reminder, the “One Big Beautiful Bill Act” (OBBBA) provides an above-the-line...more

Ballard Spahr LLP

Finally Received the Employee Retention Credit? Now What? A Guide to ERC Income Tax Consequences

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It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

Ballard Spahr LLP on

On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Husch Blackwell LLP

Impending IRS Workforce Cuts Mean Taxpayers Should Act Now to Resolve IRS Issues

Husch Blackwell LLP on

The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Jones Day

U.S. Tax Court Invokes Loper Bright for the First Time

Jones Day on

The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

Cooley LLP

Startups, Other R&D-Heavy Companies May Face Significantly Higher Tax Costs in 2022

Cooley LLP on

The Tax Cuts and Jobs Act was enacted more than five years ago, but certain changes under the legislation are only now coming into focus as taxpayers prepare their 2022 tax returns. In particular, there are significant...more

Snell & Wilmer

What’s in the Cloud? Proposed IRS Rules for Digital and Cloud Transactions

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The long wait is over – the Internal Revenue Service (IRS) has finally issued proposed regulations (the Cloud Regulations) addressing the tax treatment of cloud transactions. Until now, there was no guidance specifically...more

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