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The Solicitor General Embraces Phantom Tax Regulations

TweetShareSharePin0 Shares Today we welcome back Professor Andy Grewal, the Orville L. and Ermina D. Dykstra Professor in Income Tax Law at the University of Iowa College of Law. In this post, which originally appeared in the blog Notice & Comment, Professor Grewal discusses the Sixth Circuit decision in Whirlpool v Commissioner, Whirlpool’s  petition for

Inflation Reduction Act EU Tax & Trade Cooperation: EV Tax Credit

TweetShareSharePin0 Shares Over the last six months, European perceptions of the Inflation Reduction Act have been a rollercoaster. European policymakers were hopeful that the Inflation Reduction Act would implement Janet Yellen’s Pillar Two commitment at the Organisation for Economic Cooperation and Development (OECD). But hope turned to disappointment when the final text was fundamentally different from

CA Sides With Newsom, Votes “NO” on Millionaire’s Tax

TweetShareSharePin0 Shares California’s millionaire’s tax — opposed by Governor Gavin Newsom (D) — was voted down in yesterday’s midterm election. Newsom came under fire from some labor groups and community organizations recently when he joined California Republicans in opposing Proposition 30. The measure, had it passed, would have raised taxes on high earners in the

Mass. Millionaire’s Tax Vote Too Close to Call

TweetShareSharePin0 Shares The highly-publicized millionaire’s tax that was on the Massachusetts ballot yesterday is still making headlines, as the vote was too close to call. Reporting out of Boston, CBS News shared that the millionaire’s tax — ballot question No. 1 — would add an amendment to the state constitution imposing a 4% surtax on the amount

Practitioner Perspectives series to continue within IRS Appeals

TweetShareSharePin0 Shares News PROCEDURE & ADMINISTRATION By Martha Waggoner The IRS Independent Office of Appeals will continue its Practitioner Perspectives series as part of its focus guide for fiscal year 2023, the office’s chief said.   During the series, tax practitioners share insights and feedback with Office of Appeals employees. Recordings of panel discussions

Maryland Digital Advertising Tax Struck Down by Circuit Court

TweetShareSharePin0 Shares As Maryland’s elected comptroller, Peter Franchot (D) is technically the defendant in two cases challenging the state’s first-in-the-nation digital advertising tax, whether he likes it or not. These days, he doesn’t seem too happy about it. In a statement issued after a Maryland circuit court ruled against the tax on three separate grounds,

Federal Estate Tax Returns: IRS Data

TweetShareSharePin0 Shares Supporters of the federal estate tax often defend it by saying that “because it only affects the heirs of the wealthiest Americans—fewer than one in 1,000 estates—the estate tax is the most progressive part of the tax code.” Despite the relatively small number of estates that pay the tax, there are real people

Consequences of the (Fake) Notice of Intent to Levy

TweetShareSharePin0 Shares At the recent Fall ABA meeting there was a panel discussing Collection Appeals (which Christine was a panelist on). A discussion arose about the purpose of the CP504 “Notice of Intent to Levy,” since it is not a “real” notice of intent to levy for IRC § 6330 purposes. It is, however, a

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