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‘Power concedes nothing without a demand:’ the OECD, the G77 and a UN framework convention on tax proposal

TweetShareSharePin0 Shares With the OECD tax reforms having lost most of their original ambition, and the remaining benefits captured almost entirely by a few larger OECD members, attention is switching to the search for alternatives. In October, the G77 – by far the largest of all the ‘G’ country groups – once again tabled at

New R&D credit documentation applies to amended returns

TweetShareSharePin0 Shares A recent IRS legal memo specifying information that taxpayers must provide starting early next year in a claim for refund for a tax credit under Sec. 41 for increasing research activities (research and development, or R&D credit) applies to claims on amended returns only, said Holly Paz, deputy commissioner of the IRS Large

Depositions in Tax Court

TweetShareSharePin0 Shares Unlike in district court where depositions play an integral role in litigation, depositions in Tax Court occur with much less frequency.  The Tax Court recently issued an order allowing the IRS to take the depositions of two witnesses via Zoom in the case of Oconee Landing Property, LLC et al v. Commissioner, Dk.

Automatic extension for furnishing health coverage statements proposed

TweetShareSharePin0 Shares The IRS proposed to permanently allow an automatic extension of time for employers to furnish employees with statements about their health insurance coverage, in proposed regulations (REG-109128-21) posted to the IRS website on Monday. The proposed regulations also would make other changes to requirements under the Patient Protection and Affordable Care Act (PPACA),

Florida Gas Tax: DeSantis Gas Tax Relief Proposal

TweetShareSharePin0 Shares Florida Governor Ron DeSantis (R) knows how to make a splash, and his proposal to suspend the state’s gas tax—temporarily, but without a specific end date—will only burnish that reputation. Citing rising prices at the pump and the state’s substantial revenue surplus, the governor is calling upon the legislature to take the state’s

Briefs in the Boechler Case

TweetShareSharePin0 Shares 0 Flares Filament.io Made with Flare More Info“> 0 Flares × The Boechler case involves the issue of whether the time period for filing a Tax Court petition in a Collection Due Process case is jurisdictional or a claims processing rule.  Last week I provided

Ohio Gross Receipts Tax Repeal

TweetShareSharePin0 Shares Coming out of the pandemic, the state of Ohio is estimating significant tax revenue growth, and a group of Ohio lawmakers is looking to take advantage and repeal the Commercial Activity Tax (CAT). Ohio’s CAT, implemented in 2005 as part of tax reform that lowered and consolidated business taxes, is one of only

Sustainable Mississippi Income Tax Reduction

TweetShareSharePin0 Shares Thanks to increased tax revenues from higher consumer spending, sustained economic growth, and both the primary and secondary effects of federal COVID-19 relief programs, many states are flush with cash, and a significant number have used at least some of their surplus to provide tax relief. Many Mississippi lawmakers would like to join

What’s in a Name?

TweetShareSharePin0 Shares Identifying and addressing implicit and explicit biases are necessary to ensure that every taxpayer and tax professional recieves the benefits of “The Right to Quality Service” and “The Right to a Fair and Just Tax System.”  This free ABA outreach event at the ABA’s 38th National Institute on Criminal Tax Fraud and the

Cursive! Foiled Again

TweetShareSharePin0 Shares Bob Kamman provided another Tax Court order worth a brief mention but mostly worth the great title that he also provided.  Here, the parties use the wrong font for the petitioner’s signature and the Court sends the decision back to be redone. While this may seem picky, there’s a slippery slope that the
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