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  • Podcast

    GeTtin’ SALTy Episode 86 | Is Public Law 86-272 Still Relevant? Joyce, Finnigan, and New State Tax Challenges

    Nikki Dobay and John Ormonde examine the boundaries of Public Law 86-272's protection against state income taxation, analyzing how Massachusetts's Finnigan apportionment rule may conflict with the statute and what this means for combined corporate groups. The discussion extends to state treatment of internet activities, California's regulatory approach, and whether 86-272's protections could reach beyond tangible personal property sales.
    United StatesTax
    Greenberg Traurig
    Greenberg Traurig
  • Article

    Government Drops Statute Of Limitations Defense In McKesson Cost-sharing Challenge

    The US Department of Treasury defends its authority to regulate stock-based compensation in cost-sharing arrangements under IRC § 482, arguing the regulations fall within statutory bounds and are necessary to ensure arm's-length results between related parties. The government's response to McKesson Corporation's summary judgment motion addresses challenges based on the Loper Bright decision and notably abandons its six-year statute of limitations defense.
United StatesTax
McDermott Will & Schulte
McDermott Will & Schulte
  • Article

    Health Care Reform And Tax-Exempt Hospitals

    Health care reform is the current top agenda item for the Senate Finance Committee.
    United StatesTax
    Blank Rome LLP
    Blank Rome LLP
  • Article

    Highway Funding Bill Changes Annual US Return Filing Deadlines

    President Obama signed a short-term highway funding bill in July that includes several tax-raising provisions.
    United StatesTax
    Grant Thornton
    Grant Thornton
  • Article

    "Hot Interest" for Large Corporate Underpayments

    "Large corporate under-payments" exceeding $100,000 are subject to a "hot interest" rate that is 2 percent higher than the normal rate for underpayments
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    House of Representatives Holds Hearings on Hospital Tax Exempt Status, Charges and Billing Practices

    Last week, two separate U.S. House of Representatives subcommittees held hearings regarding hospital charges and billing and collection practices. The House Ways and Means Subcommittee on Oversight also considered under what conditions a non-profit hospital should be able to retain its tax-exempt status. The committees are considering whether hospitals should be required to disclose their prices and whether some hospitals are overcharging the uninsured and subjecting them to "aggressive" colle
    United StatesTax
    Vinson & Elkins LLP
    Vinson & Elkins LLP
  • Article

    House Tax Bill Eliminates Tax-Exempt 501(c)(3) Bonds

    This prohibition would become effective January 1, 2018, and will affect both new money and refunding bonds.
    United StatesTax
    Reinhart, Boerner, Van Deuren SC
    Reinhart, Boerner, Van Deuren SC
  • Article

    House Votes To Pay For Highways With Mortgage Reporting And Limits On The Basis Of Inherited Assets

    The House of Representatives voted 312 to 119 on July 15 to approve a highway spending bill that would raise $5 billion with a revenue title that expands reporting on mortgage interest...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    House Ways And Means Committee Votes To Make Six Expired Provisions Permanent

    The House Ways and Means Committee passed a series of bills last week that would permanently extend six of the 50-plus tax provisions that expired at the end of 2014.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    House Ways And Means Members Endorse ‘Patent' Box Proposal

    The idea of a reduced rate for IP has gained traction in recent months. It's meant to encourage the development and retention of IP in the United States and discourage foreign takeovers of U.S. companies for tax purposes.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    How Will My Business Be Taxed?

    Starting a business can be both exciting and stressful for any new entrepreneur, and perhaps nothing adds more initial stress than the word "taxes."
    United StatesTax
    Fox Rothschild LLP
    Fox Rothschild LLP
  • Article

    In Gillette, The Michigan Court Of Appeals Upholds Retroactive Repeal Of The Multistate Tax Compact

    On September 29, 2015, a three-judge panel of the Michigan Court of Appeals unanimously affirmed a lower court decision upholding Michigan's retroactive repeal of the Multistate Tax Compact (MTC).
    United StatesTax
    Dykema Gossett
    Dykema Gossett
  • Article

    Inside The New York Budget Bill Part Five: Net Operating Losses And Tax Credits

    This is the fifth installment of a series that takes an inside look at the corporate tax reform proposals in Governor Andrew Cuomo's 2014–15 New York Budget Bill.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    IRA "Charitable Rollover" Retroactively Extended Through 2014

    As a part of the so-called "Cromnibus" bill, Congress has extended dozens of expired "temporary" tax breaks for 2014.
    United StatesTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    IRS Advice Analyzes Timing Of COD Income

    The IRS has concluded in a technical advice memorandum (TAM 2013-21-019) that a debtor incurred income from the discharge of indebtedness when a court order terminated the creditor’s rights to seek any amounts related to the debt.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Allows Partnership Continuation

    In partially redacted field attorney advice (FAA 20132101F), the IRS has determined that a partnership continued in the form of a new local law entity after a series of transactions.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Chief Counsel Concludes Conditional Deficit Restoration Obligation Does Not Shift Partnership Liabilities

    In Chief Counsel Advice (CCA) 202628009, released on July 10, 2026, the Internal Revenue Service concluded that a limited partner’s conditional obligation to restore a deficit capital account does not constitute...
    United StatesTax
    Liskow
    Liskow
  • Article

    IRS Eases Burden For Noncalendar Year FSAs To Comply With $2,500 Contribution Limit

    The IRS has issued guidance (Notice 2012-40) on the new $2,500 limit on employee contributions to a health flexible spending arrangement (FSA), and it will ease the compliance burden for employers with a noncalendar plan year.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Gives Some Non-Filers One Last Chance

    As we noted in an earlier alert, organizations that failed to file returns for tax years 2007, 2008, and 2009 will automatically lose their exempt status this year.
    United StatesTax
    Dinsmore & Shohl LLP
    Dinsmore & Shohl LLP
  • Article

    IRS Includes Partnership Gross Receipts In Worthless Stock Deduction Gross Receipts Test

    The IRS has ruled that a foreign corporation should include its distributive share of foreign partnerships gross receipts.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Showing 521–540 of 3726 results

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