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Amundsen Davis LLC

Does My Company Qualify for Wisconsin’s Voluntary Disclosure Program?

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Taxes and their applicable laws can be confusing for even the most savvy businesspeople. For any number of reasons, businesses and individuals fall out of compliance with tax reporting requirements and become exposed to...more

DLA Piper

Top Ten State Tax Considerations for Israeli Companies Operating in the US

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Although Israeli companies operating in the US often focus on federal tax concerns, US state and local taxes (SALT) have the potential to significantly increase tax liabilities. For example, if a company does not collect...more

Husch Blackwell LLP

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

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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

Jones Day

New Proposed Regulations Address Spin-Off Transactions

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These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...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

Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

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The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

McDermott Will & Schulte

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Cadwalader, Wickersham & Taft LLP

Crossing the U.S. Trade or Business Line

YA Global Investments, LP (“YA Global”), a foreign investment fund that provided funding to portfolio companies in exchange for stock, convertible debentures, promissory notes and warrants, engaged U.S.-based Yorkville...more

Jones Day

IRS Updates Fast-Track Program for Certain Corporate Tax Rulings

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A new program offers rulings in 12 weeks, even absent a showing of business need. Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, Jan. 3, 2023

Legislative Lowdown - Lawmakers Look to 2023 for Tax Priorities Following Omnibus Passage. On Dec. 29, President Joe Biden signed the nearly $1.7 trillion Consolidated Appropriations Act of 2022 into law, funding the...more

Morgan Lewis

Planning for the Massachusetts ‘Millionaires Tax’

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The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more

Freeman Law

Tax Court in Brief | Palmarini Inc. v. Commissioner, Palmarini v. Commissioner | Recordkeeping and Constructive Dividends

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The Tax Court in Brief – December 12th – December 16th, 2022 - Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Freeman Law

International Tax Concepts: Dual-Status Taxpayers

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A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...more

Miller Nash LLP

A Non-U.S. Company’s Guide To Doing Business in the U.S.: Understanding Federal Taxes

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The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust economy and a strong market for imported...more

Rivkin Radler LLP

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

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Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

Freeman Law

The Tax Court in Brief - September 2021 #2

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Tax Court Cases: The Week of August 30 – September 3, 2021 - Karson C. Kaebel v. Comm’r, No. 16171-18P, T.C. Memo 2021-109 | September 9, 2021 | Halpern | Dkt. No. 16171-18P - Tax Dispute Short Summary: This case focuses on...more

Freeman Law

The Tax Court in Brief - May 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of May 3 – May 7, 2021 - Chancellor v. Comm’r, T.C. Memo....more

Foodman CPAs & Advisors

High-Income Individuals And Corporate Tax Returns Are Targets Of IRS Additional Funding Program

The 2022 discretionary funding request (request) made by the Biden Administration will invest in a “fair and robust” tax system that includes tax compliance enforcement directed at High Income and High Net  Worth Individuals...more

Gerald Nowotny - Law Office of Gerald R....

Taxing Times - April 2021

Male Escort Gets 21 Months In Prison For Tax Case - He lied on his tax returns, resulting in a tax loss to the IRS of $278,325. A male escort who lied to the IRS about his income was sentenced to 21 months in prison and...more

BakerHostetler

[Podcast] What Does a Broken Tooth Have to Do with Nexus Studies?

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In this week's episode, Matt Hunsaker equates regular state tax nexus studies with regular visits to the dentist. Things can go bad if you skip either. Learn more about what goes into a nexus study and why now is the best...more

Jones Day

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

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A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

Freeman Law

The Tax Court in Brief - November 2020

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Seyfarth Shaw LLP

The Secretary of Treasury Selects April 1 as the Effective Date for purposes of the Tax Credits under the Families First...

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Seyfarth Synopsis: The tax credits afforded to certain employers and self-employed individuals by the Families First Coronavirus Response Act (FFCRA) are in effect for the period from April 1, 2020 to December 31, 2020. ...more

Foley Hoag LLP

Update: April 15th Federal Income Tax Return Filing and Payment Deadlines Postponed to July 15th

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The IRS and Treasury issued new guidance that supersedes earlier guidance relating to the postponement of the April 15, 2020 tax deadline due to the COVID-19 pandemic. On Friday, the IRS and Treasury announced that both the...more

McDermott Will & Schulte

Weekly IRS Roundup March 16 – 20, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 16 – 20, 2020. March 17, 2020: The IRS published Rev. Rul. 2020-9 to provide various...more

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