tax Archive
Revisiting Supervisory Approval For Accuracy Penalties
May 25, 2021
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TweetShareSharePin0 Shares Today’s post comes from University of Minnesota Law student, Patrick Riley Murray. Mr. Murray is not actually one of my students in my Federal Tax Procedure or the Federal Tax Clinic courses. However, Mr. Murray was referred to me by a student and previous Procedurally Taxing contributor Casey Epstein (see post here), as
Progress On A Global Corporate Tax Rate?
May 25, 2021
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TweetShareSharePin0 Shares Will there be a global deal on corporate taxation of multinationals later this year? The Financial Times reports that Group of Seven countries is closing in on an agreement. France, Germany and Italy think the US offer of a15 percent global minimum tax could set the stage for an international deal by July.
State Taxation of GILTI: Impact of Biden Tax Proposals
May 25, 2021
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TweetShareSharePin0 Shares Key Findings Twenty states and the District of Columbia tax some portion of Global Intangible Low-Taxed Income (GILTI), although only 16 of those states have issued guidance on the matter more than three years after the federal law went into effect. States that have not yet issued guidance on their treatment of

Sorting out tax exempts’ UBTI painlessly
May 24, 2021
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TweetShareSharePin0 Shares Two digits are mostly better than six In comments to the IRS on the proposed regulations, the AICPA called for much broader two-digit codes to eliminate the complexity posed by using six, and opposed mandating the codes’ use. The new silo requirement originally “created a lot of confusion and left people guessing,” Heller
Death and Taxes
May 24, 2021
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TweetShare1SharePin1 Shares On the substantive side of tax issues Congress is focusing on death and taxes as it studies and debates whether to eliminate the stepped up basis currently given to property upon the death of the owner. This debate is not new. When I was in law school in the mid-1970s taking a class
Biden Looks To Deal on Infrastructure and The Corporate Minimum Tax
May 24, 2021
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TweetShare1SharePin1 Shares Scaling back infrastructure. In an effort to woo GOP support, President Biden offered to scale back his infrastructure bill from about $2.2 trillion to about $1.7 trillion. But Republicans say they won’t accept such a plan. Biden said he’d trim some increases in traditional infrastructure spending. Senate Republicans, who have proposed about $568
The Fourth Circuit and the Primacy of Refund Offsets in Bankruptcy
May 21, 2021
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TweetShare1SharePin1 Shares We welcome guest blogger Michelle Drumbl. Professor Drumbl runs the tax clinic at Washington & Lee Law School and teaches tax there as well. She started as a clinician at almost the same time I did, and it has been a pleasure to work with her over the years. Starting later this summer

TPC Compares President Biden’s Tax Agenda With Candidate Biden’s: Where It Differs and Where It Tracks
May 21, 2021
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TweetShare1SharePin1 Shares When Joe Biden ran for president, his campaign platform included dozens of relatively specific tax proposals. They ranged from expanding refundable tax credits for low- and moderate-income households to increasing payroll taxes for high-income workers to major changes in the way the US would tax multinational corporations. And, with a few notable exceptions,
Calling the Number Provided in IRS Correspondence
May 20, 2021
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TweetShareSharePin0 Shares This has been a tough year for the IRS. For a variety of reasons not the least of which is the pandemic, it has faced numerous challenges. My understanding is that its performance in answering the general phone line during the filing season ranged somewhere between 2-5% which is not good but it’s

President Biden & Vice President Harris Have Released Their Tax Returns
May 20, 2021
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Bob Mason, CPA
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