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In the first episode of GeTtin' SALTy in 2024, host Nikki Dobay is joined by GT Shareholder Shail Shah to catch-up on some significant 2023 cases and what to expect in 2024.

The IRS has issued a private letter ruling (PLR 2012-28-023) taking the unusual position of applying the open transaction doctrine and ruling that no debtor corporation in a consolidated group filing for Chapter 11 bankruptcy would realize COD (cancellation of debt) income until either the debtor corporation made all the distributions required under the bankruptcy plan or the bankruptcy plan ceased to be a plan of liquidation for federal income tax purposes.

On November 19, 2020, Treasury and the IRS issued final regulations under section 512(a)(6) of the tax code.

The IRS has issued 2014 draft instructions to Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, which include a transitional rule for payments subject to the Foreign Account Tax Compliance Act (FATCA) applicable after July 1, 2014.

As an individual or business, it is your responsibility to be aware of and to meet your tax filing/reporting deadlines.

As an individual or business, it is your responsibility to be aware of and to meet your tax filing/reporting deadlines.

With the pending rate cute, most companies are waiting until reform goes through to do a deal, but there are some relatively unpublicized provisions that may make deal makers rethink that strategy...

The New Jersey Tax Court has held that the gain from a deemed asset sale was non-operational income and therefore not subject to apportionment.

On December 4, 2013, the Treasury Department and the Internal Revenue Service released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal withholding tax on certain equity-linked payments.

On October 13, 2020, the Oregon Department of Revenue ("DOR") issued a temporary administrative order amending OAR 150-305-0460 to allow paper returns, statements, or documents to be signed through a facsimile method.

Article from Waller's Media Mentions.

Section 336(e) of the Internal Revenue Code of 1986, as effectuated by the final regulations promulgated in May 2013, is obviously an important corporate tax provision.

Article from Waller Law.

Article from Waller Law.

New BFH rulings bring greater certainty to the taxation of management equity participation. The court confirms that related income is generally treated as capital income rather...

Section 704(c)(1)(A) is a seemingly modest provision.

In recent years, record numbers of foreign students have enrolled in graduate and undergraduate programs at U.S. colleges and universities.

As an individual or business, it is your responsibility to be aware of and to meet your tax filing/reporting deadlines.