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  • Article

    Taxpayers Putting Pressure On Courts to Establish The IRS's Burden Of Proof In Offshore Disclosure Cases

    The case involved the appropriate burden of proof the Internal Revenue Service must meet when the IRS asserts a willful failure to file penalty for the Report of Foreign Bank and Financial Accounts.
    United StatesTax
    Dentons
    Dentons
  • Article

    Texas Comptroller Limits Application Of Controversial Data Processing Tax On Electronic Commerce Fees

    The Texas Comptroller has issued an executive order that fundamentally changes how data processing taxes apply to electronic commerce transactions, specifically targeting marketplace and platform fees that have been subject to controversial taxation. This policy shift addresses a longstanding issue where businesses faced potential double taxation on marketplace transactions, with both the platform fee and the underlying sale being taxed separately.
    United StatesTax
Jones Walker LLP
Jones Walker LLP
  • Article

    The Augusta Rule: Sweeping Up The Greens

    The Augusta Rule is a lesser-known tax strategy despite its relatively simple structure and effective results.
    United StatesTax
    EPGD Business Law
    EPGD Business Law
  • Article

    The Changing Pennsylvania Tax Landscape For Remote Work

    Businesses with employees in Pennsylvania should be prepared to adapt to a post-COVID-19 world now that temporary guidance regarding remote work has expired and pre-pandemic rules regarding...
    United StatesTax
    Ballard Spahr LLP
    Ballard Spahr LLP
  • Article

    The Check May Soon Be In The Mail: Mcconnell Introduces Tax Relief Legislation

    On Thursday, Senate Majority Leader Mitch McConnell introduced tax relief legislation, which includes among other benefits
    United StatesTax
    Lowndes
    Lowndes
  • Article

    The Estate Tax Increase Looms Amid Shortage Of Qualified Lawyers

    Stuart Morris discusses the need to recruit and retain trusts and estates attorneys in Florida with the influx of Americans relocating to the state and the Biden administration's anticipated tax exemption looming...
    United StatesTax
    Cozen O'Connor
    Cozen O'Connor
  • Article

    The Ghost Of DEMPE Past, Present, And Future

    Multinational enterprises face the complex challenge of allocating entrepreneurial profits from brands among legal entities based on their DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) value contributions. This article presents a solution to measuring the impact of historic DEMPE contributions to a brand's current value, using a case study where DEMPE functions shifted following an acquisition.
    United StatesTax
    NERA
    NERA
  • Article

    The Historic Tax Credit Safe Harbor - Part I

    Revenue Procedure 2014—12 (the "Rev Proc") issued by the Internal Revenue Service creates a safe harbor for investors in the Federal Historic Tax Credit.
    United StatesTax
    Duane Morris LLP
    Duane Morris LLP
  • Article

    The Key Tax Issues for US Employers Assigning Staff to Canada

    US employers who send US-based employees to work on assignment north of the border in Canada are likely to come into contact, directly or indirectly through their employees, with a number of tax, economic and regulatory challenges.
    United StatesTax
    Alliott Group (International)
    Alliott Group (International)
  • Article

    To Avoid FATCA Withholding, Foreign Financial Institutions Must Register With IRS By April 25, 2014

    The Foreign Account Tax Compliance Act requires foreign financial institutions to disclose the foreign accounts of U.S. taxpayers to the Internal Revenue Service.
    United StatesTax
    Hunton Andrews Kurth LLP
    Hunton Andrews Kurth LLP
  • Article

    Treasury Adopts Regulations Clarifying Opportunity Zone Tax Incentive

    The Treasury adopted final regulations that will clarify the Opportunity Zone tax incentive for certain equity interests.
    United StatesTax
    Hogan Lovells Cadwalader
    Hogan Lovells Cadwalader
  • Article

    Treasury Department Issues Guidance On Payroll Tax Deferral

    On August 28, 2020, the U.S. Department of the Treasury issued guidance for employers with respect to the deferral of the employee portion of certain payroll taxes.
    United StatesTax
    Smith Gambrell & Russell
    Smith Gambrell & Russell
  • Article

    Treasury Finalizes And Significantly Modifies Debt-Equity Regulations Under Section 385

    New final and temporary regulations under Section 385, addressing the treatment of related-party debt, significantly narrow parts of the controversial proposed regulations released in April.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Treasury Proposes Removal Of Certain Section 385 Regulations

    On Friday, September 21, 2018, the Treasury Department issued proposed regulations removing the portion of the final Section 385 regulations dealing with the documentation requirements that must be satisfied ...
    United StatesTax
    Butler Snow LLP
    Butler Snow LLP
  • Article

    Treasury Working On Further Inversion Guidance Aimed At Earnings Stripping

    Treasury officials said last week that the agency is still working on more guidance aimed at stemming the flow of U.S. companies reorganizing as foreign entities.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Trump Accounts For Kids: Insights From Wall Street Journal On Savings Options

    The Wall Street Journal recently featured insights from Evan Morgan, CPA and a principal at Kaufman Rossin's tax advisory services, on the introduction of Trump accounts for kids. (should be PR)...
    United StatesTax
    Kaufman Rossin
    Kaufman Rossin
  • Article

    Understanding The Stock Buyback Excise Tax

    As part of the Inflation Reduction Act (P.L. 117-169), Congress introduced a 1% excise tax on all stock buybacks occurring after December 31, 2022. However, Internal Revenue Code section...
    United StatesTax
    Ivins, Phillips & Barker
    Ivins, Phillips & Barker
  • Video

    Update On Tax Reform's Impact On Fringe Benefits

    Partners Judith Wethall and Finn Pressly discuss the impact of tax reform on popular fringe benefit programs including relocation costs and pre-tax transportation programs.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Podcast

    U.S. Tax Law Update: Research And Development Implications (Podcast)

    Anumber of recent changes to U.S. tax law stemming from H.R. 1, also known as the One Big Beautiful Bill, are greatly impacting innovators, specifically those with research and experimentation expenditures.
    United StatesTax
    Buchanan Ingersoll & Rooney
    Buchanan Ingersoll & Rooney
  • Article

    US Treasury Releases Final Regulations For $7,500 EV Tax Credit, Maintains Exclusions For Foreign Entities Of Concern

    On May 3, the US Treasury Department (Treasury) released final regulations under Section 30D of the Internal Revenue Code.
    United StatesTax
    Katten
    Katten
  • Showing 941–960 of 9341 results

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