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The Tax Court granted the IRS’s motion for partial summary judgment in Hewlett-Packard Co. v. Commissioner (139 T.C. No. 8), ruling that Hewlett-Packard (HP) was required to include nonsales income (i.e., dividends, interest, rents and other income) in its R&D tax credit computations.

Ultimately, the Tax Court rejected Marvel's arguments that the plain language of Section 108 proved that Congress intended that consolidated groups use a separate-entity approach.

The Tax Court of New Jersey issued a decision today finding that the throwout is Constitutional on its face.

The Tax Court has held in favor of the taxpayer in Rent-A-Center v. Commissioner (142 TC 1), allowing Rent-A-Center to claim a Section 162 deduction for payments to a Bermuda captive insurance company.

The Tax Court has ruled in "H&M, Inc. v. Commissioner" that wages paid to an individual were not disguised purchase price payments to a corporation in connection with the sale of assets.

The Tax Cuts and Jobs Act ("TCJA") is a treasure trove of tax law changes which may (at least temporarily) reduce the tax liability of businesses. One area of tax benefit for businesses is the TCJA expansion of the expenses which may be immediately expensed.

Previously, the PTC expired on Dec. 31, 2013, resulting in a significant slowdown in the development of new wind projects in 2014.

On September 27, 2010, President Obama signed into law the Small Business Jobs and Credit Act of 2010 (the "SJBCA"), which includes a temporary exclusion for 100% of the gain recognized by non-corporate investors from the sale of qualified small business stock ("QSBS") acquired after September 27, 2010 and before January 1, 2011.

The Tennessee Department of Revenue issued Notice 13-06 in June notifying taxpayers that its acceptance of voluntary disclosure of intangible expense deductions at a preferred settlement rate will be ending later this year.

As artificial intelligence transforms business operations, multinational enterprises face critical questions about where value is created when significant human functions are automated. This analysis examines how the arm's length principle should be applied to controlled transactions involving AI tool development and deployment, with particular focus on risk control functions and the attribution of AI investments across evolving value chains.

The Second Circuit Court of Appeals has weighed in on a critical tax question affecting partnership and LLC owners, affirming a narrow interpretation of who qualifies as a "limited" partner exempt from self-employment tax. This decision creates potential conflict with the Fifth Circuit's approach, raising questions about whether the Supreme Court will need to resolve the split and provide definitive guidance on this important issue for business owners.

The Foreign Account Tax Compliance Act requires foreign financial institutions to disclose the foreign accounts of U.S. taxpayers to the Internal Revenue Service.

Grant Thornton LLP has been a strong advocate for taxing all business income at the same rate, regardless of entity.

Treasury and the IRS recently issued final regulations (T.D. 9737) under Section 851(c), which relates to regulated investment company (RIC) controlled group rules.

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...

Treasury has stated that a large impetus for the proposed changes was to address base erosion and profit shifting by multinational companies.

Treasury officials said last week that the agency is still working on more guidance aimed at stemming the flow of U.S. companies reorganizing as foreign entities.