aallenlenth Archive

TweetShareSharePin0 Shares The Sixth Annual Tax Controversy Institute will be held online on Friday, July 16th, 2021. The virtual institute is sponsored by the University of San Diego School of Law and the tax law firm RJS Law. The event will be free of charge and will allow practitioners to earn free education credits. Speakers

TweetShareSharePin0 Shares Pinning down whether an activity is a trade or business for tax purposes, whether a tax penalty should be waived for reasonable cause, or the eternal question of when income is recognized for tax purposes — these issues arise often, and CPAs can benefit from being familiar with the judicial doctrines governing them.

TweetShareSharePin0 Shares 0 Flares Filament.io Made with Flare More Info“> 0 Flares × Our post today features an Op Ed that Les wrote reacting to the Pro Publica release of information.  Because Les is on vacation, I have the opportunity to introduce his post which he asked

TweetShareSharePin0 Shares President Biden and G-7: Yes to a global minimum corporate tax of 15 percent. Biden and leaders of the Group of 7 nations publicly endorsed on Friday a 15 percent minimum global corporate tax rate. They also agreed to replace individual country digital services taxes with a destination tax based on where multinational

TweetShareSharePin0 Shares I wrote about documents bouncing back from the Tax Court last month in connection with the Tax Court policing the timely filing of petitions.  The post caused commenter in chief Bob Kamman to pay careful attention to the orders coming out of the Tax Court and he noticed a particularly bad day for

TweetShareSharePin0 Shares In new final regulations (T.D. 9950), Treasury and the IRS have attempted to resolve ambiguities about when a federally declared disaster will lead to a mandatory 60-day postponement of certain time-sensitive tax-related deadlines. The final regulations adopt, with some changes, proposed regulations issued in January (REG-115057-20). The mandatory postponement provision, Sec. 7508A(d), was

TweetShareSharePin0 Shares We are starting to see some fallout from last month’s CIC Services opinion. For example, Tax Notes’ Kristen Parillo discusses[$] Hancock Land Acquisitions v US , another microcaptive case. Parillo’s article explores the parties’ post CIC Services supplemental filings in a case where the taxpayer brought an action alleging that the IRS’s failure to refer its case