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© 2026 Legalease Ltd. All rights reserved

Registered company in England & Wales No. 02427356 VAT GB 321 5727 22

Registered address: 188 Fleet Street, London, EC4A 2AG

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  • Article

    Financier Worldwide Indepth Features Global Tax 2026

    Clark Armitage and Jose Perez examine critical shifts in US international tax policy, including changes to GILTI and FDDEI regimes that fundamentally alter how multinational enterprises structure their operations. The analysis explores how political priorities around economic competitiveness are reshaping enforcement approaches and transfer pricing strategies for companies operating across borders.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Five Strategies To Cut Your Company's 2023 Tax Bill

    As another year ends with interest rates and markets in flux, one thing remains certain: Reducing your company's tax bill can improve your cash flow and your bottom line.
    United StatesTax
    ORBA
    ORBA
Article

Former QSUB Cannot Prorate Post-Termination Items Of Income Or Loss

The IRS Office of Chief Counsel addressed whether an S corporation and its wholly owned qualified subchapter S subsidiary must prorate annual income.
United StatesTax
Grant Thornton LLP
Grant Thornton LLP
  • Article

    Franchisors May Be Subject To Iowa Corporate Income Tax If Franchisees Are Located In Iowa

    Those in the franchising industry have been awaiting a ruling from the Iowa Supreme Court in KFC Corp. vs. Iowa Department of Revenue, a tax nexus case that could have implications for the entire industry.
    United StatesTax
    Larkin Hoffman Daly & Lindgren
    Larkin Hoffman Daly & Lindgren
  • Article

    Gillette Wins California Multistate Compact Case In Court Of Appeal

    In 1966, the California Legislature adopted the Uniform Division of Income for Tax Purposes Act.
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Article

    IRS Authorizes Negligence Penalty For Treating Open-Air Garage As Land Improvement

    The IRS has released field attorney advice that authorizes a negligence penalty on a taxpayer for taking the position that an open-air garage is a land improvement and therefore has a 15-year recovery period.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Concludes Exterior HVAC Units Not Qualified Leasehold Improvement

    The IRS has concluded in a legal memorandum that the installation of exterior heating, ventilation and air conditioning units on roofs and concrete pads next to buildings does not meet the definition of a qualified leasehold improvement property under Section 168(e)(6).
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Concludes Guarantee Is An Amount ‘At Risk’ Under Section 465

    The IRS has concluded in a legal memorandum that an individual's guarantee was an amount at-risk for purposes of Section 465.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Final Regulations On Form 990

    The IRS substantially redesigned the Form 990 in 2008 and issued temporary regulations relating to those changes on Sept. 9, 2008.
    United StatesTax
    McGuireWoods LLP
    McGuireWoods LLP
  • Article

    IRS Issues Proposed Regulations Affecting Publicly Traded Partnerships Engaged In Minerals And Natural Resource Activities

    Generally, an entity that is a PTP is classified as a corporation for U.S. federal income tax purposes under Section 7704.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Proposed Regulation On Tax-Exempt Schools And Other Nonprofits' Diversity Initiatives

    The Treasury Department and IRS have proposed a regulation that would revoke federal tax-exempt status for private educational institutions with policies or practices deemed to discriminate on the basis of race, including diversity-related programs. The rule eliminates previous safe harbors and raises significant questions about the scope of prohibited activities, potentially affecting scholarships, fellowships, and pipeline programs at schools nationwide.
    United StatesTax
    WilmerHale
    WilmerHale
  • Article

    IRS Publishes New Form For Tax-Exempt Organization Determinations

    On August 8, the IRS released a new one page Form 8940, Request for Miscellaneous Determination, to obtain advance approval on certain activities.
    United StatesTax
    McGuireWoods LLP
    McGuireWoods LLP
  • Article

    LB&I Issues Directive For Cable Network Assets

    The IRS Large Business and International Division (LB&I) issued a directive instructing examiners to discontinue exam activity and not begin new activity related to certain expenditures to maintain, repair or improve cable network property.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Maintaining S Corporation Status – Getting Easier And Less Costly

    Preventing a late or invalid S corporation election or termination is a high priority for S corporations, their owners, and their advisors.
    United StatesTax
    Capes Sokol
    Capes Sokol
  • Article

    Mississippi Legislature Passes Significant Tax Relief

    On April 18, 2016, the Mississippi Legislature passed Senate Bill 2858 and enacted the "Taxpayer Pay Raise Act of 2016."
    United StatesTax
    Butler Snow LLP
    Butler Snow LLP
  • Article

    More Guidance On Accountable Care Organizations Needed From IRS

    In a letter dated May 31, to Sarah Hall Ingram, Commissioner for Tax Exempt and Government Entities – the American Hospital Association (AHA) asked the IRS to make it clear that participating in an accountable care organization (ACO) will not result in impermissible inurement or private benefit to tax-exempt nonprofit hospitals and will not generate unrelated business income tax (UBIT) if the entity involved is in compliance with the Centers for Medicare and Medicaid Services’ (CMS) eligibility
    United StatesTax
    McGuireWoods LLP
    McGuireWoods LLP
  • Article

    New Bill Will Radically Change Ohio Property Tax Appeals

    Under a new bill adopted by the Ohio General Assembly, school boards, governmental bodies, and other third parties will be prohibited from filing complaints to increase the value of others' Ohio real property...
    United StatesTax
    Dinsmore & Shohl LLP
    Dinsmore & Shohl LLP
  • Article

    New Jersey Enacts Law Encouraging Angel Investments in Emerging Technology Companies

    On January 31, 2013, New Jersey Governor Chris Christie signed into law the New Jersey Angel Investor Tax Credit Act.
    United StatesTax
    Duane Morris LLP
    Duane Morris LLP
  • Article

    New York Governor Cuomo Signs Sweeping Corporate Tax Reform Legislation

    On March 31, 2014, New York State Governor Andrew M. Cuomo signed into law comprehensive New York State corporate tax reform legislation.
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Article

    New York State Tax Department Releases Guidance On Tax Reform Legislation

    Under the new law, related corporations may, and may be compelled to, file combined returns if they are engaged in a unitary business.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
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