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In Person Hearing Inconveniences Appeals Witness

TweetShareSharePin0 Shares As is often the case, commenter in chief, Bob Kamman, brought to my attention an order that prior to DAWSON would probably have received the designated order label.  DAWSON did away with designated orders, as we have discussed before, but did not stop the Tax Court from issuing important and interesting orders.  The

Changing ways of working call for changing employment and tax policy

TweetShareSharePin0 Shares The way individuals work for pay has transformed radically in recent years, but employment practices and tax treatment remain largely frozen in outmoded assumptions and models. Annette Nellen, Esq., CPA, CGMA, will examine changing work models and proposals for change in “Should Everyone Be an Employee? Policy for the Modern Workforce,” on Tuesday,

Subordination of Tax Lien Denied

TweetShareSharePin0 Shares In the bankruptcy case of In re Baldwin, 128 AFTR 2d 5762 (Bankr. N.D. Ohio 2021) the trustee’s attempt to use the subordination provisions of BC 724(b) fail because the bankruptcy court determines that selling the debtor’s house would not benefit the unsecured creditors of the estate and would harm the debtor’s wife

Effect of Bankruptcy Confirmation on Tax Liability

TweetShareSharePin0 Shares In Wathen v. Commissioner, TC Memo 2021-100 the taxpayer argued that the confirmation of his chapter 13 plan precluded the IRS from subsequently pursuing a deficiency case for periods not included in the plan.  Petitioner represented himself in this case which brings its own limitations on the understanding of procedure.  This was his

IRS issues inflation adjustments for 2022 returns

TweetShareSharePin0 Shares News PROCEDURE & ADMINISTRATION By Paul Bonner The IRS issued Rev. Proc. 2021-45 Wednesday, adjusting for inflation a wide array of amounts applicable to the 2022 tax year for use with individual, business, and estate and trust returns and related tax issues. Amounts under 62 Code sections are updated. The IRS also

Indonesia Tobacco Tax Design: Indonesia Cigarette Tax

TweetShareSharePin0 Shares Indonesia, the world’s second-largest cigarette market, has a uniquely complex system when it comes to taxing its tobacco consumption, which is almost exclusively cigarettes (98 percent). The country’s cigarette taxes are divided into no less than 10 rate tiers based on product type, volume, and price. These tiers are meant to protect smaller

Maryland Digital Advertising Tax Regulations: Tax Foundation Comments

TweetShareSharePin0 Shares Note: The following comments were submitted to the Maryland’s Comptroller’s office on November 8th, 2021 regarding the regulation of Maryland’s Digital Advertising Tax. The Maryland digital advertising tax, applied to gross revenue derived from digital advertising services, has a rate escalating from 2.5 percent to 10 percent of the advertising platform’s assessable base

Passport Revocation Cases Part 2

TweetShareSharePin0 Shares Yesterday, I discussed two recent passport revocation cases, United States v. Hupp and Franklin v. United States. Today, I look at Tenth Circuit and Tax Court cases involving similar issues decided earlier this year. Rowen The Tax Court decision in Rowen v. Commissioner, 156 T.C. No. 8 (2021) addresses the constitutionality of the

Imposing Standards: Lessons from tax history about the ‘global tax deal’

TweetShareSharePin0 Shares The OECD’s triumphal announcement of the Inclusive Framework tax reforms last month was followed in close succession by the larger G77 group of countries tabling a proposal in United Nations negotiations for a genuinely inclusive intergovernmental tax body under UN auspices. Martin Hearson is a research fellow at the ICTD who has studied
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