tax Archive

Chile Tax Reform Heads in the Wrong Direction

TweetShareSharePin0 Shares The Tax Foundation recently released the 2022 International Tax Competitiveness Index (ITCI), measuring the complexity and neutrality of countries’ tax systems. Over the years, Chile has consistently remained in the lower half of the Index’s rankings, and in the 2022 version of the Index, Chile fell from 26th to 27th (out of 38

Why TPC Revised Its Estimates Of The Business Tax Proposals Pending In the Post-Election Congress

TweetShareSharePin0 Shares The Tax Policy Center has revised its estimates of the revenue cost and distributional effects of the business tax cuts included in its analysis of several tax changes currently pending in the post-election session of Congress. TPC analyzed the effects of eliminating a scheduled phase-down in 100 percent bonus depreciation. However, TPC incorrectly

What’s Wrong With The Tax Court Hallmark Opinion: Part 2

TweetShareSharePin0 Shares In this post, I will discuss the legislative history undergirding the argument over which provision provides the Tax Court’s deficiency jurisdiction and point out things that the Hallmark opinion oddly decided not to discuss about this legislative history, even though the taxpayer presented this information to the court. The Hallmark opinion (slip opinion

Who Would Benefit From Restoring The Full CTC, EITC, and The TCJA’s Business Tax Breaks?

TweetShareSharePin0 Shares This blog has been revised, reflecting TPC’s recalculated analysis of proposals to reduce business taxes that are under discussion in Congress. TPC’s initial analysis over-estimated the revenue loss of these provisions and their benefits to households. The lame duck Congress will spend the next several weeks arguing over the fate of several key

The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 1)

TweetShareSharePin0 Shares Today’s guest post is the first of a two-part series by Megan L. Brackney. These posts raise important questions about practitioners’ ethical responsibilities when confronting clients’ potential exposure to penalties for failing to file foreign information returns. Megan previously wrote a terrific series of posts considering problems with the IRS’s administration of these

The California Office of Tax Appeals Weighs in on Boyle and Electronically Filed Returns

TweetShareSharePin0 Shares Today’s guest blogger is Joseph Cole, LL.M.  He is an Associate Attorney at RJS Law in San Diego, California.  His practice includes federal and state tax controversy. Today’s post discusses a recent California case applying the Boyle doctrine to an electronically filed return.  Like many cases applying the Boyle doctrine, the California case

Jury Deliberates After Prosecutors Allege Donald Trump Knew About Tax Fraud

TweetShareSharePin0 Shares The 12-person jury in the Trump Organization criminal trial begins deliberations today, Monday, December 5, after the prosecution alleged that Donald Trump knew about the tax fraud scheme while it was occurring. Credit: Michael M. Santiago/Getty Images During closing arguments on Friday, Assistant District Attorney Joshua Steinglass told jurors in Manhattan Criminal Court, “Donald

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