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Plunkett & Cooney
In a previous post, we covered injured spouse relief as an option for a taxpayer who saw their refund used by the IRS to offset tax debt incurred by their spouse before the marriage.
A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax-related factors that need to be considered...
Holland & Knight
Gov. Bill Lee recently signed into law Public Chapter 950, which creates significant changes in how Tennessee's franchise tax is calculated.
Holland & Knight
The Liberty Global Inc. v. United States appeal has practitioners and taxpayers concerned that the economic substance doctrine will be applied to disallow the tax benefits of ordinary course of business...
Buckingham, Doolittle & Burroughs
The costs associated with hiring attorneys, defending a lawsuit, and paying for damages or a settlement can be exorbitant, and will inevitably damage a company's profitability.
Alvarez & Marsal
Virginia has long-standing research and development (R&D) tax credits in place aimed at incentivizing innovation within the state. The credits are provided to businesses and individuals engaged...
Caplin & Drysdale
What are current trends in US tax disputes? How can you reduce litigation risk? What is the Supreme Court likely to make of Moore, a case that could call into question large swathes of the US tax system?
Katten Muchin Rosenman LLP
It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign...
Holland & Knight
The U.S. Department of the Treasury and IRS on April 25, 2024, released the final regulations under Section 6418 of the Internal Revenue Code regarding the transfer of tax credits.
Greenberg Traurig, LLP
A problem with Florida's Live Local Act property tax exemption statute for multifamily middle-income affordable units has been revealed...
Ankura Consulting Group LLC
In this article, we delve into the intricacies of valuing individual legal entities as part of a legal entity rationalization, exploring some of the key considerations that must be considered to prepare a robust...
Holland & Knight
The USTC has affirmed it will adhere to its decision that the IRS lacks authority to assess Section 6038(b) penalties in cases falling under other circuits of the U.S. Courts of Appeals.
Greenberg Traurig, LLP
On April 12, 2024, as required under I.R.C. § 7431, the Internal Revenue Service notified over 70,000 taxpayers that their tax return information was subject to a data breach perpetrated by an IRS...
Kelley Drye & Warren LLP
As noted in our prior advisory, U.S. citizens and residents who receive gifts exceeding certain thresholds from foreign persons must generally report such gifts to the IRS on Form 3520...
Alvarez & Marsal
On the same day many company installments were due, the IRS and Treasury granted limited penalty relief for underpaying estimated tax installments based on the corporate alternative minimum tax.
Alvarez & Marsal
It's increasingly evident that companies are seeking to design supply chains and operating models that are flexible, resilient and can improve tax efficiency.
Sheppard Mullin Richter & Hampton
The Inflation Reduction Act enables corporate taxpayers to purchase and use against their own federal income tax liability the federal income tax credits generated by other taxpayers from the construction...
Greenberg Traurig, LLP
In this episode of GeTtin' SALTy, host Nikki Dobay is joined by Brad Scott, director of finance at Halstead Beads, to discuss where sales tax collection requirements are at six years after the landmark Wayfair decision.
Jones Day
The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs.
Mayer Brown
On April 9, 2024, the US Department of the Treasury and the Internal Revenue Service issued long-awaited proposed regulations under Section 4501 of the Internal Revenue Code...
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