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  • Article

    Certain Litigation Costs Are Ordinary And Necessary Business Expenses, IRS Rules

    In a private letter ruling (PLR 201412002), the IRS ruled that certain costs incurred by a corporate taxpayer to settle a lawsuit, including settlement payments and legal fees, were deductible as ordinary and necessary business expenses under Section 162.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Choice Of OVDP Program- Irrevocable?

    Several taxpayers sued the IRS to remove them from the OVDP program and allow them entrance into the streamline program, an alternative program open to taxpayers after July 1, 2014.
    United StatesTax
    Dentons
    Dentons
  • Article

Class Action Stayed

The Pennsylvania Superior Court (which rarely addresses tax issues) held that a trial court correctly ruled that a purported class action for the refund of Sales and Use Tax
United StatesTax
Cozen O'Connor
Cozen O'Connor
  • Article

    Conflicting Court Decisions Could Seriously Affect Health Plans

    Two appeals courts released opposing decisions that could profoundly affect whether employers will face penalties for failing to meet the health coverage requirements.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Congress Passes Passport Revocation Bill Aimed At Large Tax Debtors

    On December 4, 2015, the President signed into law HR 22, which requires the IRS to notify the State Department of any U.S. citizen who owes more than $50,000 in federal taxes.
    United StatesTax
    Sheppard
    Sheppard
  • Article

    Congress Targets Partnership Disguised Sales And Services

    Both the House's and Senate's budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are self-executing in the absence of regulations
    United StatesTax
    Hogan Lovells Cadwalader
    Hogan Lovells Cadwalader
  • Article

    Coronavirus: Treasury Secretary Mnuchin Announces 90-Day Interest-Free And Penalty-Free Tax Payment Extension From April 15 To July 14

    Today, March 17, 2020, Treasury Secretary Steven Mnuchin announced that individuals may defer up to $1 million in 2019 tax liability without interest or penalties until July 14...
    United StatesTax
    Proskauer Rose LLP
    Proskauer Rose LLP
  • Article

    Court Of Appeals Rules 23-Day Notice Requirement For Third Party Summonses Is Mandatory In Tenth Circuit

    Taxpayer Sam Jewell was the subject of an IRS investigation which resulted in third party summonses being issued to banks located in Oklahoma.
    United StatesTax
    BakerHostetler
    BakerHostetler
  • Article

    COVID-19 Relief For Tax-Exempt Bonds: Telephonic Public Hearings Extended To September 30, 2021

    The IRS released Revenue Procedure 2020-21, which provided relief for issuers seeking to do a public hearing for their bonds amidst the COVID-19 pandemic, on May 4, 2020.
    United StatesTax
    Ballard Spahr LLP
    Ballard Spahr LLP
  • Article

    CRS Registration Now Required For Certain UK Investment Managers — Action Needed By 31 December 2025

    The International Tax Compliance (Amendment) Regulations 2025, which came into force on 16 July 2025, introduce a new requirement for UK investment managers to register under...
    United StatesTax
    Dechert
    Dechert
  • Article

    Data Protection And The Swiss – DOJ Settlement Program

    The program for non-prosecution agreements for Swiss Banks is largely settled.
    United StatesTax
    Dentons
    Dentons
  • Article

    Deadline Extended for 2010 Charitable IRA Rollover

    On December 17, 2010, Congress passed legislation that, among other items, extends the charitable IRA rollover until December 31, 2011. The charitable IRS rollover allows people aged 70 ½ and older to transfer up to $100,000 of their IRA assets for each of 2010 and 2011 directly to a qualified public charity.
    United StatesTax
    Dinsmore & Shohl LLP
    Dinsmore & Shohl LLP
  • Article

    Decision On Florida CDD Has Broad Implications For Tax-Exempt Bonds

    The IRS issued a Technical Advice Memorandum on May 9, 2013, that the Village Center Community Development District is not a division of state or local government, and therefore is not a political subdivision for purposes of Section 103 of the Internal Revenue Code.
    United StatesTax
    Holland & Knight
    Holland & Knight
  • Article

    Delaware Alert: State Issues More VDA Invitation Letters For Unclaimed Property

    The Delaware Secretary of State's office announced they have issued letters to companies on or around April 11, 2025, inviting them to enter into the Delaware voluntary disclosure agreement (VDA)...
    United StatesTax
    Marcum
    Marcum
  • Article

    Delayed FBAR Filing For Signatory Authority

    As reported in our prior client alerts, the Report of Foreign Bank and Financial Accounts, Form TD-F 90-22.1 ("FBAR") must be filed by a U.S. person that holds a financial interest in, or signature or other authority over, a foreign financial account if the aggregate value of all such U.S. person's foreign financial accounts exceeds $10,000 at any time during the year.
    United StatesTax
    Proskauer Rose LLP
    Proskauer Rose LLP
  • Article

    Delivery Charges Excluded From Missouri Sales And Use Taxes Effective August 28

    On July 5, Governor Eric Greitens signed into law Missouri Senate Bill 16, which excludes "usual and customary delivery charges" from sales and use taxes. The law will become effective on August 28, 2017.
    United StatesTax
    Brown Smith Wallace
    Brown Smith Wallace
  • Article

    Did You Know That The Qualified Opportunity Zone Tax Credit Has Been Permanently Extended And (At Least Arguably) Enhanced?

    The QOZ tax credits were enacted in 2017 and sunset on December 31, 2026. This credit allows taxpayers to defer until December 31, 2026...
    United StatesTax
    Taft, Stettinius & Hollister LLP
    Taft, Stettinius & Hollister LLP
  • Article

    Did You Know That You Can File A Section 83(b) Election With The IRS Electronically?

    Section 83(b) allows taxpayers to elect to include in their current taxable income certain compensation that would not otherwise be taxable until a future year.
    United StatesTax
    Taft, Stettinius & Hollister LLP
    Taft, Stettinius & Hollister LLP
  • Article

    Did You Know That You Can Make A Like-kind Exchange Into An Interest In A Delaware Statutory Trust?

    It is widely understood that you can defer taxation of the gain on a sale of investment real estate if the sale proceeds are reinvested into new investment...
    United StatesTax
    Taft, Stettinius & Hollister LLP
    Taft, Stettinius & Hollister LLP
  • Article

    Dold Weighs In On Final RMD Regulations With Tax Notes

    Groom's Elizabeth Thomas Dold, principal, was featured by Tax Notes in the article, "IRS Keeps Contentious Required Minimum Distribution 10-Year Rule," where she examined final regulations from the IRS...
    United StatesTax
    Groom Law Group, Chartered
    Groom Law Group, Chartered
  • Showing 761–780 of 9341 results

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