tax Archive
Credit Carry Forward as Timely Refund Claim
September 13, 2021
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TweetShareSharePin0 Shares In Libitzky v. United States, No. 3:18-cv-00792 (N. D. Cal. 2021) the district court dismisses cross motions for summary judgment in a refund suit and pushes the case forward for a determination by a jury. The parties agree that the Libitzkys overpaid their 2011 liability by almost $700,000. They disagree on the issue
Does the Malta/US Tax Treaty Exempt Malta Pension Plans?
September 13, 2021
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TweetShareSharePin0 Shares Malta/US Treaty on Tax-Free Roth & Maltese Pensions Malta/US Treaty on Tax-Free Roth & Maltese Pensions Is the Maltese Treaty for Tax-Free Pension Illegal: At the current time, even though the Internal Revenue Service listed the Malta/US Tax Treaty on the Dirty Dozen list when it is being used for tax-free pension benefits
Tax on Stock Buybacks a Misguided Way to Encourage Investment
September 10, 2021
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TweetShareSharePin0 Shares Stock buybacks have gained a bad rap in recent years as policymakers have blamed them for a range of economic ills, from encouraging a focus on short-term profits to reduced investment. Now, Senators Ron Wyden (D-OR) and Sherrod Brown (D-OH) have targeted buybacks for a 2 percent excise tax in the reconciliation package.
Keeping Child Tax Credit Fully Refundable Is Critical to Low-Income Families
September 10, 2021
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TweetShareSharePin0 Shares As Congress debates whether to extend the major, but temporary, changes to the Child Tax Credit (CTC) it adopted earlier this year, a crucial question is whether it should keep the credit fully refundable. A new Tax Policy Center analysis finds that, for low-income families, full refundability is a key element of the
Applying the Penalty Approval Provision to a Conservation Easement Case
September 10, 2021
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TweetShareSharePin0 Shares In Oconee Landing Property LLC et al v. Commissioner, Dk. No. 11814-19 the Tax Court entered a very substantive order granting partial summary judgment to the IRS on the issue of penalty approval. If the Court still designated orders, I suspect it would have designated this one. The IRS in this case uses
Was The Senate’s Heated Crypto Tax Reporting Debate Much Ado About Nothing?
September 10, 2021
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TweetShareSharePin0 Shares When Congress debates major legislation, the public often focuses on a single narrow issue—one frequently irrelevant to the main point of the bill. It happened when the Senate debated the $1 trillion infrastructure measure last month: Many paid outsized attention to tax reporting for cryptocurrency, a proposal that would have funded less than
A Second Bite at the Innocent Spouse Apple
September 9, 2021
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TweetShareSharePin0 Shares We regularly have clients who come into the Tax Clinic at the Legal Services Center of Harvard Law School who received a determination in the past that they did not qualify for innocent spouse relief. These individuals may have what looks to us like a good case, but we struggle to get them
Tax Justice Network Arabic podcast: الجباية ببساطة #45 – لبنان ما بعد الإفلاس
September 9, 2021
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TweetShareSharePin0 Shares Welcome to the 45th edition of our Arabic podcast/radio show Taxes Simply الجباية ببساطة contributing to tax justice public debate around the world. It’s produced and presented by Walid Ben Rhouma and is available on most podcast apps. Any radio station is welcome to broadcast it for free and websites are also welcome to share it. You can follow
Treasury Minimum Tax Argument Relies on Narrow Interpretation of Rules
September 8, 2021
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TweetShareSharePin0 Shares Tuesday, the U.S. Treasury Department released a blog authored by Treasury officials Itai Grinberg and Rebecca Kysar. Though the blog purports to make a case for President Biden’s proposal to increase the current minimum tax on foreign profits of U.S. companies, its arguments rely on a very narrow interpretation of current law and
Guidance issued on 2021 wage reporting of qualified sick and family leave
September 8, 2021
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TweetShareSharePin0 Shares The IRS on Tuesday detailed how employers must report qualified sick leave wages and qualified family leave wages for leave provided to employees in 2021. Under Notice 2021-53, employers are required to report the qualified leave wages on either box 14 of a 2021 Form W-2, Wage and Tax Statement, or on a
