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Senate Finance Committee Chair Orrin Hatch, R-Utah, acknowledged last week that his corporate integration proposal is running into difficulties that will postpone its release until at least May.

Two months after our oral argument, the Appellate Court of Illinois on October 7th reversed a Circuit Court decision and held that Wendy's International did not have to include its insurance subsidiary in its Illinois combined income tax returns.

The Illinois Department of Revenue (Department) announced that it will grant abatement of late filing penalties for taxpayers that file their Illinois business income tax returns...

Implications Of Tax Reform On Tax-Exempt Organizations

In 2017, Congress passed the Tax Cuts and Jobs Act, which—among other things—placed a $10,000 annual limit on state and local tax (SALT) deductions for federal income tax purposes.

The recent Tax Cuts and Jobs Act has revolutionized the U.S. taxation of international income earned from outbound investment and business operations.

The American Taxpayer Relief Act of 2012 extends—and makes retroactive—the ability of non-corporate investors to exclude from federal taxable income 100% of the eligible gain realized from the sale of "qualified small business stock".

In United States v. Quality Stores, Inc., 134 S. Ct. 1395 (2014), the U.S. Supreme Court ruled that severance payments at issue in the case were wages subject to Federal Insurance Contributions Act (FICA) taxes.

The IRS recently released guidance acquiescing to the Ninth Circuit's opinion that unmarried domestic partners are each individually entitled to deduct interest on up to $1,000,000 of home acquisition debt...

The Internal Revenue Service and the U.S. Treasury Department scheduled a public hearing to discuss proposed regulations under section 385 of the Internal Revenue Code.

This is good news, which removes a concern some had raised about making larger gifts now.

In a chief counsel advice memorandum the IRS considered whether interest that is accrued but not paid is "United States property" under Section 956.

In 2017, Congress amended Section 451(b) of the tax code to require accrual method taxpayers to include certain amounts in income...

On September 29, 2020, Treasury and the IRS issued final regulations under section 274 of the tax code that address the deductibility of business meal and entertainment expenses.

The IRS has issued a private letter ruling providing that a taxpayer’s net positive and negative income under Treas. Reg. 1.1502-21(f)(2), from a subsidiary with separate return limitation year net operating losses, was included in the computation of consolidated taxable income for a SRLY subgroup of a consolidated group.

On October 13, 2016, the Treasury Department and the Internal Revenue Service (IRS) issued final and temporary regulations under section 385 of the Internal Revenue Code.

The IRS on Feb. 27 issued final regulations under Section 41(c)(5) for electing the alternative simplified credit (ASC).

Jeremy M. Pelphrey was quoted in the Standard Federal Tax Reports – Taxes On Parade article "IRS Issues Guidance On Expansion Of In-Plan Roth Rollovers Under ATRA."