Mondaq USA: Tax > Tax Authorities
Morrison & Foerster LLP
With the failure of health care legislation to "repeal and replace" the Affordable Care Act, eyes in Washington, D.C. are now turning to tax reform. Since Congress plans to take August off...
Shearman & Sterling LLP
The US Tax Court rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in a US business will not be treated as "effectively connected income"...
Bowditch & Dewey
A good point of sale ("POS") system is critical for any business engaged in sales to the public and having one in place goes a long way to ensuring that revenue and profits are being reported...
Grant Thornton LLP
The Treasury Department has delayed for one year the effective date of the documentation requirements under the Section 385 regulations...
McDermott Will & Emery
Lessons learned from the first legislative season in which the Revised Uniform Unclaimed Property Act was considered, and in some cases adopted in part.
Cadwalader, Wickersham & Taft LLP
The Democrats vowed they would not back a tax reform plan that "includes tax cuts for the top one percent."
McDermott Will & Emery
In the last Congress, the Business Activity Tax Simplification Act of 2015 (BATSA) would have codified a physical presence requirement in the context of business activity taxes (e.g., net income and gross receipts taxes).
Grant Thornton LLP
On July 13, 2017, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3 (2017), the U.S. Tax Court held that gain recognized by a nonresident partner...
Ostrow Reisin Berk & Abrams
When owners, managers and salespeople attend trade shows, call on customers and evaluate suppliers, they may incur travel and entertainment expenses.
Shearman & Sterling LLP
The documentation rules would have originally applied to debt instruments issued or deemed to be issued on or after January 1, 2018.
Cadwalader, Wickersham & Taft LLP
The White House released a joint statement (the "statement") with congressional Republican leadership expressing a "shared vision" for comprehensive tax reform.
Grant Thornton LLP
The Pennsylvania Commonwealth Court recently held that a local business privilege tax imposed on fees paid by Pennsylvania 7-Eleven franchise stores to 7-Eleven's regional office in Upper Moreland Township...
Herrick, Feinstein LLP
Because of the supremacy of federal law, many bankers and other professionals assume that federal tax liens would take priority over state law liens, regardless of when the latter arose or were perfected
Shearman & Sterling LLP
The New Notice extends the effective date for certain rules in those final regulations and extends the phase-in period provided last December, in Notice 2016-76 (the "2016 Notice")...
Grant Thornton LLP
On May 24, 2017, the New Jersey Tax Court granted a taxpayer's motion for summary judgment and allowed deductions for royalty payments made by a subsidiary to its parent company.
Grant Thornton LLP
On June 28, 2017, New Hampshire Gov. Chris Sununu signed a budget bill which updates the Internal Revenue Code (IRC) conformity date and increases the IRC Section 179 depreciation expense deduction limitation.
McDermott Will & Emery
This, according to the IRS, was fatal to any claim by the taxpayers to refined coal credits related to the LLC's production of refined coal.
K&L Gates
In a recently published decision, the U.S. Tax Court declined to follow the longstanding position of the U.S. Internal Revenue Service ("IRS"), articulated in Revenue Ruling 91-32
Stoll Keenon Ogden PLLC
The Kentucky Claims Commission recently held that tax credits awarded under Section 42 of the Internal Revenue Code ("IRC") must be excluded from the value of a low-income housing tax credit...
Grant Thornton LLP
The Michigan Department of Treasury recently released guidance acquiescing in its interpretation of the term "materials and supplies"...
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Dentons
Serving as a vivid reminder that it is vital that a taxpayer comply strictly and completely with the charitable deduction regulations, the Tax Court recently denied a $33 million charitable deduction...
Foley Hoag LLP
Did someone steal your tax return? You are not alone.
Akin Gump Strauss Hauer & Feld LLP
Recent IRS guidance requires that non-U.S. investment funds currently relying on an FFI agreement for their FATCA compliance must renew such agreement on the IRS website by July 31, 2017...
Reed Smith
Yesterday, June 15, the California Legislature approved Assembly Bill 102, a bill that drastically overhauls the role of the BOE as a tax administrator, and as the highest administrative appeal body...
Ruchelman PLLC
In Rev. Rul. 91-32, the I.R.S. announced its view that foreign partners in partnerships operating in the U.S. are properly taxed on their capital gains under a look-thru rule to the assets owned by...
Stroock & Stroock & Lavan LLP
Responding to President Donald Trump's Executive Order 13789, which called on the Secretary of the Treasury to submit an interim report identifying any significant tax regulations issued since January 1, 2016...
Grant Thornton LLP
On June 29, 2017, the California Supreme Court held that the documentary transfer tax may apply to transfers of interests in legal entities that own real estate.
Grant Thornton LLP
On June 15, 2017, just 72 hours after its publication, the California legislature passed the Taxpayer Transparency and Fairness Act of 2017, in a move that will transfer significant responsibilities...
Davies Ward Phillips & Vineberg
The Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co., SA (149 TC No. 3 (2017)) (Grecian Magnesite) has determined that gain from a non-U.S. corporation's sale of an interest in a U.S. partnership ...
Ruchelman PLLC
When claiming a refund of over-withheld tax, purchasing or selling real property, or complying with U.S. filing requirements, a non-U.S. individual is required to obtain an I.T.I.N. from the I.R.S...
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