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In Frontier Custom Builders Inc. v. Commissioner, T.C. Memo 2013-231 (Sept. 30, 2013), the Tax Court held that the taxpayer was required to capitalize all direct and certain indirect costs of production under Section 263A.

In a question of first impression for Illinois, on May 12, 2015, Judge Schmidt of the Circuit Court of Sangamon County granted a summary judgment for the Illinois Department of Revenue, holding that the proper test for corporate income tax nexus is whether a "significant economic presence" exists in Illinois.

The final regulations provide that a corporate partner with a 10% or greater interest in a partnership must allocate its direct interest expense to all of its assets.

In addition to the discussion of the Tax Court's decision in Altera, this month's issue features articles regarding Notice 2015-47 "Basket Options" and Notice 2015-48 "Basket Contracts"...

In this Ropes & Gray podcast, tax associate Brandon Dunn is joined by tax partners Kat Gregor and David Saltzman to discuss one of the most notable tax decisions from the fourth quarter of 2017 and its implications for taxpayers, particularly multinational corporations.

Senate Finance Committee Chair Orrin Hatch, R-Utah, has provided new details on his corporate integration proposal and is waiting on the Joint Committee on Taxation (JCT) for a revenue score.

Senate Finance Committee Chair Orrin Hatch, R-Utah, acknowledged last week that his corporate integration proposal is running into difficulties that will postpone its release until at least May.

Historic Rehabilitation Tax Credit And Other Tax Credit Incentive Structures In Limbo Awaiting IRS Guidance

Two months after our oral argument, the Appellate Court of Illinois on October 7th reversed a Circuit Court decision and held that Wendy's International did not have to include its insurance subsidiary in its Illinois combined income tax returns.

On July 11, 2017, the Indiana Tax Court held that the Indiana Department of Revenue erred in reclassifying a corporation's gain on a 2001 sale of a subsidiary from nonbusiness income to business income.

This is the third 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.

Governor Andrew Cuomo has signed into law a budget bill containing major corporate tax reform.

The recent Tax Cuts and Jobs Act has revolutionized the U.S. taxation of international income earned from outbound investment and business operations.

On Sept. 1, 2010, the IRS released Announcement 2010-54 to solicit applications from cooperative electric companies (cooperatives) for $190,795,445 of New Clean Renewable Energy Bond (New CREBs) volume cap.

Tax-exempt hospitals will be required in 2011 to respond to questions on financial assistance policies, billing and collection practices, emergency medical care and individuals eligible for financial assistance.

The IRS has created new procedures to allow businesses with less than $10 million in assets or annual gross receipts to apply the final tangible property regulations prospectively beginning with the first tax year on or after Jan. 1, 2014, and to make their method changes for that year without filing a Form 3115.

The IRS has finalized temporary regulations (T.D. 9594 ) under Treas. Reg. Sec. 1.1502-13(f)(5)(ii)(B) that provide an election to avoid immediate gain after certain Section 332 transactions.