Pass-Through Tax Break Backers Target Centrist Democrats
A new coalition launching Thursday will target moderate Democrats in defending a key tax break for pass-through business income.
Daily Tax Report ®
Tax Bill, Appropriations Loom as Lawmakers Come Back (Podcast)
Lawmakers return to Washington next week for the final sprint of legislating before the November elections, on the heels of a failed tax bill vote, and with an appropriations deadline fast approaching.
Warren Urges IRS Crackdown on Hotel, Hospital REIT Bad Actors
Sen. Elizabeth Warren (D-Mass.) wants the IRS to amplify its enforcement on real estate investment trusts that are skirting tax laws.
PRACTITIONER INSIGHTS
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Linda Pfatteicher
Dentons
Farhan Azeem
PKF Littlejohn
Robert Zonenshein
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Tax Developments
View MoreIRS Notice: Comments Requested Regarding Implementation of the Retirement Saver’s Match Contributions (IRC §6433)
Comments are requested regarding all aspects of the retirement Saver’s Match contributions created by §103 and §104 of the SECURE 2.0 Act of 2022, the IRS announced. Section 103 of ...
Case: IRS is Not Estopped From Asserting Taxpayer’s Ownership Interest in S Corporation Despite Her Exclusion From Bankruptcy Proceedings Involving the S Corporation (T.C. Memo) (IRC §1366)
Taxpayer, a 50% shareholder in an S corporation, was liable for tax on the business’s rental income and capital gains, the U.S. Tax Court held, sustaining the IRS’s calculations of ...
IRS News Release: Third Quarter Estimated Tax Payment Deadline Is Sept. 16
Taxpayers are reminded that the deadline to submit third quarter estimated tax payments is Sept. 16, 2024, the IRS announced. Taxpayers affected by disasters in 17 states, Puerto Rico, and ...
PODCASTS
More States Welcome Cannabis Business Tax Deductions
Undoing Microsoft's California Tax Ruling Isn't Simple
Inside EY's Generative AI Rollout and Tax Challenges
New EU Tax Panel Chair Takes Aim at Avoidance Schemes
From the Analysts
View MoreBGOV OnPoint: ‘Chevron’ Demise Changes Rulemaking, Legislating
The linked OnPoint reviews details of the June 28 US Supreme Court ruling rejecting a doctrine permitting federal courts to defer to an executive branch agency’s interpretation of an ambiguous law, overturning a 40-year-old precedent.
BTAX OnPoint: GILTI Collides with Pillar 2 Minimum Taxes
There is renewed attention on the US Global Intangible Low-taxed Income (GILTI) taxing structure and its interaction with new minimum tax rates taking effect around the world under the international Pillar 2 initiative. These taxes focus on the largest multinational companies and their cross-border operations.
BTAX OnPoint: OECD Releases Report on Pillar One - Amount B
The OECD issued a report outlining the rules under Pillar One - Amount B of its global tax deal.
Free Tax Filings Threaten $4 Billion TurboTax Business
Bloomberg Tax Journals
View MoreStructuring Tax-Efficient Trust Decantings After ‘the Guidance’
The publication of Chief Counsel Advice Memorandum 202352018 (“the CCA”) shook up the tax and estate planning community as it provided practitioners a glimpse into how the IRS may soon begin to analyze tax issues arising from a popular estate planning technique known as “trust decanting” — invading the corpus of one trust and transferring the assets into another — more than a decade after it had solicited public comments on the matter.
Tax Court Gives “Great Weight” to IRS Treaty Interpretation
The Tax Court’s Ryckman ruling applied a “great weight” deference standard to accept the IRS’s tax treaty interpretation, but the Supreme Court should weigh in after Loper overturned Chevron, notes a Gunster, Yoakley & Stewart practitioner.
Key TP Issues MNEs Must Review When Restructuring Businesses
A business must consider the transfer pricing implications for a successful business restructuring, says a KPMG Nigeria practitioner.
Latest Stories
Circuit Splits Reported in U.S. Law Week—August 2024
U.S. Law Week summarizes selected splits among U.S. federal courts of appeals each month.
Hunter Biden Pleaded Guilty to Tax Offenses, DOJ Says
Troutman Pepper, Locke Lord Partners Approve Big Law Merger
Partners at Troutman Pepper and Locke Lord this week voted in favor of the law firms merging, according to a joint statement Thursday.
Multistate Tax Commission Counsel Nancy Prosser to Leave Agency
Multistate Tax Commission General Counsel Nancy Prosser will leave the intergovernmental tax agency Sept. 24 after four years as the commission’s top legal officer, she announced Thursday.
Direct Mail Business Partners Defeat IRS’s Tax Deficiency Push
The IRS was dealt a pair of losses by the US Tax Court on Thursday, which barred as too late the agency’s tax deficiency determinations against partners in a direct-mail subscription business.
States Eye Task Force to Define Digital Goods for Tax Purposes
A multistate effort examining uniform rules for taxing the digital economy will explore the definitions of digital products and services, potentially giving states a template for expanding their sales tax bases.
Business Groups Warn Against IRS’ Broad Brush in Validity Tests
Several business groups called on the US Tax Court and other federal courts to constrain the IRS’ power to determine if transactions are legitimate or tax avoidance strategies, saying its over-enforcement could lead to wide-ranging implications that penalize businesses.
FROM ACROSS BLOOMBERG TAX
- Daily Tax Report: International
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- Transfer Pricing Report
- The Exchange: Tax Insights & Commentary
Turkey Tax Agency Seeks Comments on Proposed Amendment of Corporate Tax General Communique
The Turkish Revenue Administration Sept. 3 opened a consultation on proposed amendments to Corporate Tax General Communique No. 1, to reflect legislative changes. The proposal includes measures to incorporate: 1) ...
New Zealand Tax Agency Announces Entry Into Force Dates for DTA, Protocols With Austria, Slovakia
The New Zealand Inland Revenue Sept. 2 announced the entry into force dates of: 1) Aug. 29, 2024, for the second protocol to the 2006 DTA with Austria, signed Sept. ...
Denmark Tax Agency Clarifies VAT Exemption for Collective Investment Fund Management Services
The Danish Customs and Tax Administration Sept. 2 posted online Tax Council Binding Answer No. SKM2024.430.SR, clarifying the VAT exemption for collective investment fund (CIF) management services. The taxpayer, an ...
Guatemala Congress Considers Bill to Ratify Air Services Agreements With UAE, Qatar, Dominican Republic
The Guatemalan Congress Aug. 27 accepted for consideration Bill Nos. 6323, 6363, and 6364, to ratify the air services agreements with: 1) the United Arab Emirates, signed May 11, 2023; ...
Turkey Gazettes General Communique Clarifying Financial Statement Inflation Adjustments for 2024 Provisional Tax Periods
The Turkish Official Gazette Aug. 31 published General Communique No. 563 from the Revenue Administration, clarifying financial statement inflation adjustment procedures for specified provisional tax periods in 2024. The adjustment’s ...
Turkey Tax Agency Issues Circular Further Extending Filing, Payment Deadline for Q2 2024 Provisional Income Taxes
The Turkish Revenue Administration Aug. 29 issued Circular No. VUK-173/2024-11, extending the filing and payment deadline to the end of Sept. 13, from the end of Sept. 6, for Q2 ...
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