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Thinking Out Loud About the Advanced CTC – Part 2

TweetShareSharePin0 Shares In my last blog post, I identified some of the challenges that arise when the Child Tax Credit is converted from an annual pay-out to a monthly pay-out. In this blog post, I will explore some alternative approaches that may address, if not resolve, those challenges. I have to confess that I am muddling through

Thinking Out Loud About the Advanced Child Tax Credit – Part I

TweetShareSharePin0 Shares With the recent launch of a campaign to get people who are not usually networked with the federal tax system to sign up for the Advanced Child Tax Credit (AdvCTC), the Administration, Congress, and advocates are focusing on what a permanent AdvCTC would look like.  Some child welfare and anti-poverty advocates are promoting the concept of

TEFRA + LCU = Confusion, Part 1

TweetShareSharePin0 SharesWe invite back guest blog writer Bob Probasco for a three-part collection influenced by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement insurance claim as unexpected under TEFRA, although the insurance claim would certainly have been prompt under the conventional durations of area 6511. Component 1 establishes the phase and also takes

TEFRA + LCU = Confusion, Part 3

TweetShareSharePin0 Shares In today’s post Bob Probasco concludes his three-part series on General Mills and the intersection of TEFRA and “hot interest.” Part One can be found here. Part Two, here. Christine In Part 1, I described the decision by the Court of the Appeals for the Federal Circuit in General Mills, Inc. v. United

TEFRA + LCU = Confusion, Part 2

TweetShareSharePin0 Shares In Part Two of this three-part series, Bob Probasco examines the dissenting view in the recent General Mills case out of the Federal Circuit. Part One can be found here. Christine In Part 1, I described the decision by the Court of the Appeals for the Federal Circuit in General Mills, Inc. v.

TEFRA + LCU = Confusion, Part 1

TweetShareSharePin0 Shares We welcome back guest blogger Bob Probasco for a three-part series inspired by the Federal Circuit’s recent 2-1 decision tossing General Mills’ refund claim as untimely under TEFRA, although the claim would have been timely under the standard timeframes of section 6511. Part 1 sets the stage and examines the majority’s reasoning. Christine

Approving Presents from the Internal Revenue Service: Moral Factors To Consider (Sequel)

TweetShareSharePin0 SharesFormerly, we reviewed both groups of Internal Revenue Service “presents” that taxpayers can decline: clerical presents and also totally computational presents. We left, nonetheless, with the cliffhanger that computational presents might end up being “theoretical” presents, which lawyers frequently can approve. Today, we’ll look better at what a theoretical present is and also whether

Approving Presents from the Internal Revenue Service: Honest Factors To Consider (Component One)

TweetShareSharePin0 SharesFor questions on this and other tax issues please visit ETS @ Executive Tax Solution Formerly, I blogged about the unusual instance of Owner v. C.I.R (here). As a refresher course, the Householders attempted to take around half-a-million bucks in rubbish reductions for their steed breeding/leasing “company,” as well as the Tax obligation Court
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