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Searching Content indexed under Tax by Roger Jones ordered by Published Date Descending.
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IRS Rules (Again) That Taxpayers Are Not Entitled To Claimed Refined Coal Credits
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.
United States
11 Aug 2017
2
APA Challenge To Notice Of Deficiency: QinetiQ Oral Arguments
On October 26, 2016, the US Court of Appeals for the Fourth Circuit heard oral argument in QinetiQ U.S. Holdings, Inc. v. Commissioner, No. 15-2192.
United States
4 Nov 2016
3
Altera Corporation Files Answering Brief In Commissioner's Ninth Circuit Appeal Of Altera
In Altera Corp v Commissioner, 145 TC No. 3, the Tax Court, in a unanimous reviewed opinion, held that regulations under Section 482 requiring parties to a QCSA to include stock-based compensation...
United States
21 Sep 2016
4
3M Company, IRS File Reply Briefs In "Blocked Income" Case; Tax Court Orders Oral Argument
3M returns to its argument that Treas. Reg. § 1.482-1(h)(2) is "procedurally invalid" because Treasury and the IRS failed to satisfy the requirements of section 553 of the APA when they promulgated the regulations.
United States
8 Sep 2016
5
Sixth Circuit Defines ‘Corporation' For Purposes Of Overpayment Interest
The Sixth Circuit held that a nonprofit entity incorporated under state law falls within the definition of a ‘corporation' for purposes of determining the interest rate applicable to tax refunds.
United States
23 Aug 2016
6
Law School Professors File Amicus Briefs In Support Of Commissioner's Position In Altera
One group of six professors first notes its agreement with the arguments advanced by the government in its opening brief.
United States
5 Aug 2016
7
Supreme Court Issues Opinion Addressing Interplay Between APA Procedural Compliance And Chevron Difference
In Encino Motorcars, LLC v. Navarro, Sup. Ct. No. 15-415 (June 20, 2016), the Supreme Court of the United States invalidated a regulation issued by the US Department of Labor under the Fair Labor Standards Act.
United States
6 Jul 2016
8
Commissioner Files Opening Brief In Ninth Circuit Appeal Of Altera
The Commissioner's arguments on brief are very specific to the context of Reg. §§ 1.482-1(b)(1) and 1.482-7.
United States
6 Jul 2016
9
IRS Issues New Procedures To IRS Appeals For Requesting Assistance From Exam In Docketed Tax Court Case
Under the new procedures, Appeals will send a request for Exam's assistance if Appeals determines that the new information merits additional analysis or investigation.
United States
4 Jul 2016
10
Altera: How To Challenge Tax Regulations On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under section 482 requiring participants in qualified cost-sharing agreements (CSAs) to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
5 Oct 2015
11
Statute Of Limitation: Congress Overrules Home Concrete And Retroactively Removes Some Taxpayer Defenses
On July 31, 2015, President Barack Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (H.R. 3236; Pub. Law No. 114-41) (the 2015 Act) into law.
United States
20 Aug 2015
12
Altera: Tax Court Invalidates Section 482 Regulation On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
20 Aug 2015
13
The New Section 6501(c)(10) Regulations
Under § 6501(a), the IRS generally has three years from the date a tax return is filed to assess additional tax.
United States
24 Apr 2015
14
Court Weighs In On Deadline For Filing FTC Refund Claims
The U.S. Court of Federal Claims issued its opinion in Albemarle Corp. v. United States, No. 12-184T, holding that it lacked jurisdiction over the taxpayer’s claim for refunds.
United States
15 Oct 2014
15
Ensuring Timely Filing With Private Delivery Services
Most of us are aware of the timely-mailed-timely-filed "mailbox rule" contained within the Internal Revenue Code.
United States
4 Jun 2014
16
Challenging Regulations After Mayo And Home Concrete
In the wake of the Supreme Court of the United States’ recent tax opinions in Mayo Foundation for Medical Education & Research v. United States, 131 S.Ct. 1836 (2011), and United States v. Home Concrete & Supply, LLC, 132 S.Ct. 1836 (2012) taxpayers have additional arguments at their disposal to challenge U.S. Department of the Treasury regulations.
United States
6 Dec 2013
17
The 3M Case: Can The IRS Overrule The Supreme Court?
In March 2013, 3M filed a petition with the U.S. Tax Court challenging the Internal Revenue Service's determination that $23.6 million in additional royalty income should be allocated to 3M's U.S. headquarters from its Brazilian subsidiary.
United States
27 Sep 2013
18
CCRC Fees - A Primer On The Tax Treatment Of Entrance And Monthly Fees
Continuing care retirement communities (CCRCs) are professionally managed retirement communities, many of which also function as long-term skilled nursing care facilities.
United States
12 Dec 2012
19
IRS Reaffirms Commitment To Audits Of High Net-Worth Individuals
In response to a report from TRAC criticizing its relatively new Global High Wealth Industry Group, the IRS recently reaffirmed its commitment to reviewing returns of high net worth individuals.
United States
3 Sep 2012
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