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tax Archive

Limitation on Issues Taxpayer Can Raise in Passport Case

TweetShareSharePin0 Shares The case of Shitrit v. Commissioner, T.C. Memo 2021-63 points out the limitations on raising issues other than the revocation of the passport when coming into the Tax Court under the jurisdiction of the passport provision.  Petitioner here tries to persuade the Tax Court to order the issuance of a refund but gets

A Closer Look at Eliminating the Alternative Minimum Tax (AMT)

TweetShareSharePin0 Shares In the Tax Foundation’s new Options for Reforming America’s Tax Code 2.0, there are several options that would simplify the tax code, including eliminating the alternative minimum tax (AMT). While this move would remove a source of complexity, policymakers should also consider reforming the deductions that created a justification for the AMT in

How Biden Would Tax Capital Gains At Death

TweetShareSharePin11 Shares President Biden has proposed major changes in the way the US taxes the assets of those who have died. There is a great deal of confusion about just what he’d do, in part due to the way the White House itself framed his proposals in an April fact sheet. I’ll try to explain

A First Step Toward A Global Minimum Tax

TweetShareSharePin0 Shares G-7 agrees to a 15 percent  minimum corporate tax framework. The group representing seven major industrialized nations backed the concept of a global minimum corporate tax rate of at least 15 percent. Companies would pay that rate regardless of their country of residence.  Some large companies like Amazon, Facebook, or Google, would pay

A First Step Toward A Global Minimum Tax

TweetShareSharePin22 Shares G-7 agrees to a 15 percent  minimum corporate tax framework. The group representing seven major industrialized nations backed the concept of a global minimum corporate tax rate of at least 15 percent. Companies would pay that rate regardless of their country of residence.  Some large companies like Amazon, Facebook, or Google, would pay

IRC 7459(d) and the Impact of Dismissal

TweetShareSharePin11 Shares On May 20, 2021, the Court of Federal Claims decided the case of Jolly v. United States, Dk. No. 20-412.  Ms. Jolly pursued the case pro se.  The court lists the opinion as not for publication. The case involves a refund suit covering four tax years.  The court decided not to dismiss her

Is today a turning point against corporate tax abuse?

TweetShareSharePin0 Shares This is an extended version of the op-ed recently published in the Guardian. The G7 countries have the chance to strike the biggest blow in a century against the tax abuse of multinational companies. Top line agreement this today would allow the OECD to deliver a full deal over the coming months on

Is today a turning point against corporate tax abuse?

TweetShareSharePin11 Shares This is an extended version of the op-ed recently published in the Guardian. The G7 countries have the chance to strike the biggest blow in a century against the tax abuse of multinational companies. Top line agreement this today would allow the OECD to deliver a full deal over the coming months on
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