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  • Article

    How President Biden's Infrastructure Plan Could Reshape America's Energy Sector

    The energy-related proposals set forth in President Joe Biden's American Jobs Plan ("Plan"), if enacted by Congress, are set to fuel an already dynamic, evolving energy sector.
    United StatesGovernment, Public Sector
    Seyfarth Shaw LLP
    Seyfarth Shaw LLP
  • Article

    Another Year of Medical Resident FICA Refund Claims due

    The ongoing, multi-year saga of refund claims to the Internal Revenue Service (IRS) for Federal Insurance Contribution Act (FICA) taxes paid on medical resident stipends continues without resolution.
    United StatesStrategy
    McDermott Will & Emery
    McDermott Will & Emery
Article

Administrative Law Judge Affirms Holding On Alabama SRLY Rule

On August 15, 2012, Chief Administrative Law Judge Bill Thompson issued his long-awaited SRLY ruling, holding that an Alabama consolidated group was entitled to carry forward certain net operating losses incurred before the group’s election to file an Alabama consolidated return, however, Judge Thompson also held that the group could not deduct any NOLs incurred before 1999 when the consolidated filing option was not available.
United StatesTax
Bradley Arant Boult Cummings LLP
Bradley Arant Boult Cummings LLP
  • Article

    Bad Debts Are Deductible For Pennsylvania Gross Receipts Tax Purposes - Provided Proper Documentation Is Available

    The Pennsylvania Department of Revenue recently issued Corporation Tax Bulletin 2011-02.
    United StatesTax
    Reed Smith
    Reed Smith
  • Article

    BREAKING NEWS: Congress Sends Tax Cuts And Jobs Act To President Trump's Desk For Signing

    The Tax Cuts and Jobs Act (TCJA) has been passed by both houses of Congress and is now set to be signed into law by President Trump.
    United StatesTax
    Foley & Lardner LLP
    Foley & Lardner LLP
  • Article

    Congress To U.S. Corporations: GET OUT! QUICK, BEFORE IT'S TOO LATE!

    An article from Alvarez & Marsal chronicles the history of U.S. Congressional efforts to prevent U.S.-organized corporations from reorganizing outside the U.S.
    United StatesTax
    Strasburger & Price, L.L.P.
    Strasburger & Price, L.L.P.
  • Article

    False Claims Never Die In California

    Recently, AB 2570 has cleared the Assembly Appropriations Committee, which authorizes tax-based false claims actions—allowing private, profit-motivated parties to bring punitive civil enforcement lawsuits.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Federal Court Orders IRS To ‎Release Digitally Readable Forms 990

    A federal judge on January 30, 2015, handed the Internal Revenue Service (IRS) a significant defeat in its fight against releasing IRS Form 990 information returns in a digitally readable format...
    United StatesTax
    Venable LLP
    Venable LLP
  • Article

    IRS Chief Counsel Memorandum Addresses 30-Day Rule Under Section 956

    On Date 1, the CFC loaned Amount 1 to Parent. Amount 1 was outstanding on the last day of CFC's quarter including Date 1.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Extends And Clarifies Expired Safe Habor For Trusts Staking Digital Assets

    The IRS has issued new guidance addressing how investment and grantor trusts can participate in digital asset staking while maintaining their federal tax status. Revenue Procedure 2026-20 establishes updated safe harbor requirements that allow qualifying trusts to stake cryptocurrency without risking reclassification as corporations or complex partnerships, replacing earlier guidance that expired in August.
    United StatesTax
    Liskow
    Liskow
  • Article

    IRS Issues Favorable Ruling That Facility-Specific PPAS Are Part Of A Wind Facility Rather Than A Separate Asset

    In Private Letter Ruling 201214007 issued on April 6, 2012, the IRS ruled that where a taxpayer purchased wind energy facilities accompanied by facility-specific power purchase agreements ("PPAs"), no portion of the purchase price need be allocated to the PPAs as a separate asset.
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Article

    IRS Issues Safe Harbors Under Which The IRS Will Not Assert That A Corporation Lacks The Requisite ‘Control' For Purposes Of Section 355(a)

    In 2013, the IRS announced it would no longer issue such rulings while it studied the issue.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    IRS Proposes To Classify Basket Contracts As A Tax Avoidance Scheme

    The U.S. Department of the Treasury and IRS on July 11, 2024, issued proposed regulations that would classify certain basket contract transactions...
    United StatesTax
    Holland & Knight
    Holland & Knight
  • Article

    IRS Ruling Allows Multi-Line Family Business To Split Up The Business Lines Among Shareholders Tax-Free

    A common theme we see today in family-owned businesses is the ownership of several lines of business either through a parent corporation with the original business and one or more subsidiaries holding other newer...
    United StatesTax
    Liskow
    Liskow
  • Article

    Louisiana Franchise Tax - No Tax On Corporate Limited Partners With No Louisiana Nexus

    The Louisiana Court of Appeal blocked the Louisiana Department of Revenue from imposing franchise tax on a corporation.
    United StatesTax
    Hunton Andrews Kurth LLP
    Hunton Andrews Kurth LLP
  • Article

    Plain And Simple: Maryland Tax Court Holds Insurance Company Is Exempt From Corporate Income Taxes

    Maryland, like many states, exempts "insurance companies" from the payment of corporate income taxes because these entities are generally subject to tax under some other section of the tax law, insurance law or both.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Policyholder Dividends Deductible Under Recurring Item Exception

    In Massachusetts Mutual Life Insurance Co. v. U.S, 2015 U.S. App. LEXIS 57 (Fed. Cir. 2015), the U.S. Court of Appeals for the Federal Court affirmed the deductibility of policyholder dividends under the recurring item exception.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Qualification Procedures For The InvestOhio Tax Credit

    Ohio has a new Tax Credit program called InvestOhio.
    United StatesTax
    Ulmer & Berne LLP
    Ulmer & Berne LLP
  • Article

    Supreme Court Decides to Include Attorney’s Fees in Plaintiff’s Gross Income

    On January 24, 2005, the U.S. Supreme Court decided whether the portion of a judgment or settlement paid to a plaintiff’s attorney under a contingent fee agreement is income to the plaintiff. The Court held that the entire recovery should be included in the plaintiff’s gross income.
    United StatesTax
    Vedder, Price P.C.
    Vedder, Price P.C.
  • Article

    Texas Business Personal Property Tax Alert

    The Dallas Central Appraisal District (DCAD) is targeting trucking companies to assess Texas business personal property taxes, requiring fast action by a targeted company to timely respond...
    United StatesTax
    Strasburger & Price, L.L.P.
    Strasburger & Price, L.L.P.
  • Showing 741–760 of 3726 results

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