The taxpayer in the case sold property to commercial builders or individual buyers who would then construct homes on the property.

The IRS recently released final regulations (T.D. 9782) under Section 5000C relating to the 2% tax on payments made by the U.S. government to foreign persons pursuant to certain contracts.

The IRS and Treasury recently released final and temporary regulations (TD 9812) under Section 7874.

Both the House and Senate have passed budgets that would allow the tax-writing committees to use reconciliation procedures to expedite tax legislation.

In a Chief Counsel Advice memorandum (CCA 201623006), the IRS national office addressed whether the Financial Industry Regulatory Authority (FINRA) is a "corporation or other entity...

The IRS on Nov. 26 finalized regulations (T.D. 9643) on the annual fee imposed on health insurance providers.

The IRS has finalized proposed regulations issued in 2014 regarding the characterization of amounts when a distribution includes Roth amounts and goes to multiple destinations.

The IRS has released interim guidance on the allocation of the research and development tax credit to members of a controlled group.

The Cumulative List informs plan sponsors of requirements the IRS has specifically identified for review in determining whether Cycle A plans have been properly updated to reflect law changes.

The IRS has released a draft agreement for foreign financial institutions entering into an FFI agreement under the Foreign Account Tax Compliance Act.

The IRS recently issued its final report summarizing the results from the 401(k) compliance check questionnaire.

The IRS has issued temporary (T.D. 9654) and proposed (REG-121534-12) regulations providing guidance on the identification of certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation under the inversion rules of Section 7874.

Section 162(m) limits a public corporation's deduction for a taxable year for compensation paid to certain executives to $1 million for each executive.

The IRS Large Business & International Division has announced that it will delay the start date of new and controversial information document request procedures until March 3, 2014.

By all accounts, lawmakers should have all they need to begin writing the first comprehensive tax reform bill since 1986.

On May 2, 2017, the Michigan Tax Tribunal granted a passive holding company's motion for summary disposition and held that it did not have the requisite nexus with the city of Detroit for purposes of the CDIT.

On May 31, 2017, the Minnesota Tax Court overturned as unconstitutional the taxation of certain trusts as Minnesota "resident trusts" and held that application of the statutory definition of "resident trust"...

On April 10, 2017, New York enacted its 2017-18 budget legislation which extends the state's top personal income tax rate for an additional two years and closes several tax loopholes.

The Ohio Board of Tax Appeals (BTA) held that a taxpayer's sales were properly sitused to Ohio for purposes of the Commercial Activity Tax because the "ultimate destination" of the goods sold by the taxpayer...

Senate Finance Committee Chair Ron Wyden, D-Ore., is expected to hold a committee markup of a bill extending now-expired tax provisions — so called "tax extenders" — in early April.