tax Archive
Appeals Finalizes Team Case Leader Initiative
October 5, 2021
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The Sixth International Taxpayer Rights Conference kicked off today with a workshop on ombuds and advocates and continues through Friday. As Nina Olson mentioned last week in Taxpayer Rights as Human Rights: Registration is

House Democrats Tax Increases in Historical Context: Build Back Better
October 4, 2021
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TweetShareSharePin0 Shares One way to put the House Build Back Better Act’s tax increases in historical context is to compare them to previous tax increases as a share of gross domestic product (GDP). Compared to previous tax changes, this House tax plan would impose the largest gross tax increase since President Lyndon Johnson’s tax hike

Proposed Top Combined Marginal Capital Gains Tax Rate Would Be Third-Highest in OECD
October 4, 2021
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TweetShareSharePin0 Shares Under the House Build Back Better Act (BBBA), the United States would tax capital gains at the third-highest top marginal rate among rich nations, averaging nearly 37 percent. In the U.S., long-term gains currently face a top marginal tax rate of 23.8 percent at the federal level, the result of a maximum 20 percent
Effective Tax Administration and Equitable Estoppel as Defenses to Assessment of Trust Fund Recovery Penalty
October 4, 2021
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TweetShareSharePin0 Shares I am confused by the court’s introduction of the case which indicates that the IRS brought suit to hold Stanley Craft liable as a responsible officer. Usually, the IRS assesses the Trust Fund Recovery Penalty (TFRP) and the responsible person brings a refund suit against the United States seeking to recover any amount

Florida Corporate Income Tax Rate: Lawmakers Should Provide Certainty
October 1, 2021
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TweetShareSharePin0 Shares Florida is now the ninth state to implement or adopt a corporate income tax cut in 2021, with the state’s new rate the nation’s second lowest—for now. Five states adopted corporate income tax cuts legislatively this year, two states (Arkansas and Indiana) implemented rate relief as part of previously enacted phased reductions, and
Knowledge Leaves Another Innocent Spouse Petitioner Standing at the Altar
October 1, 2021
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TweetShareSharePin0 Shares Goode v. Commissioner, T.C. Summ. Op. 2021-34 finds another spouse seeking relief from liability under IRC 6015 failing because of the knowledge element and the lack of economic hardship. As we discussed in the recent post entitled “Is Economic Hardship the Antidote for Knowledge in an Innocent Spouse Case?” the Tax Court has
Supreme Court Agrees to Decide Whether the CDP Petition Filing Deadline Is Jurisdictional
September 30, 2021
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TweetShareSharePin0 Shares This is an exciting development for those interested in tax procedure. We have discussed Boechler and the question of jurisdictional time limits often on Procedurally Taxing. Carl Smith blogged about the Eighth Circuit decision here. Carl explained, In Boechler, P.C. v. Commissioner, 2020 U.S. App. LEXIS 23306, on July 24, [2020], the Eighth Circuit

Federal Plastics Tax Is Not a Good Revenue Raiser
September 30, 2021
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TweetShareSharePin0 Shares One of the Senate’s proposals to pay for the Build Back Better Act is a federal excise tax on virgin plastics, which are plastics that are not reprocessed or recovered. The tax would be $0.20 per pound of virgin plastics used to make single-use plastics products. While few details have been released about

US Multinational Corporation Tax Data & Analysis
September 29, 2021
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TweetShareSharePin0 Shares Recent proposals from the Biden administration and congressional Democrats aim to hike taxes on the foreign profits of U.S. multinationals, resting on the claim that U.S. multinationals pay very low tax rates on these foreign profits. But how heavily taxed are they, and how would various proposals affect these tax rates? U.S. multinational

TPC Answers Two Questions About Its Analysis of the House Ways & Means Committee’s Tax Bill
September 29, 2021
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TweetShareSharePin0 Shares After the Tax Policy Center published its new analysis of the House Ways & Means Committee’s budget reconciliation tax plan, commentators asked two questions: Why did TPC suddenly create two sets of distributional tables: One that includes all major provisions of the bill and another that includes the individual income tax, the payroll