Civil Procedure – May 23, 2012

by Akerman Senterfitt on 5/23/2012

The recent U.S. Supreme Court decision in United States v. Home Concrete & Supply, LLC, Sup. Ct. No. 11-139 (Apr. 25, 2012) is a victory for taxpayers on the statute of limitations for federal tax assessments. The Supreme...more

by Darrin Mish, Tampa Tax Attorney on 5/16/2012

Many people were rejoicing when the Supreme Court decided in favor of Home Concrete & Supply LLC in their dispute with the IRS over the statute of limitations on tax audits. In that landmark case, the highest court in the...more

by Lane Powell PC - Taxation Law on 5/15/2012

Originally published in The Practical Tax Lawyer in Spring 2012 Generally, a state may tax the worldwide income of a person who is domiciled there. Although defined by statute or administrative rule in some states,...more

by Charles (Chuck) Rubin on 5/14/2012

For those of you with a great memory, you will remember that in December 2009 we wrote about the case of Morgens v. Commissioner. For those with a more typical memory, you can read the original post on the case here. In...more

by Fraser Milner Casgrain LLP on 5/9/2012

The Federal Court of Appeal has once again affirmed the importance of Generally Accepted Account Principles (GAAP) in computing liability for the large corporation tax (LCT) applicable prior to 2006 while rejecting the...more

by Fraser Milner Casgrain LLP on 5/7/2012

On April 23, Morguard Corporation filed an appeal with the Federal Court of Appeal of the decision of Boyle J in the Tax Court of Canada, 2012 TCC 55, (Date: February 24, 2012) holding that a $7.7 million break fee was...more

by Bracewell & Giuliani LLP on 5/3/2012

On April 11, 2012, Judge John Dietz issued a ruling from the bench in Southwest Royalties, Inc. v. Combs, Case D-1-GNU-09-004282 (Travis County 250th Dist. Ct.) to extend the Texas sales tax exemption for manufacturing...more

by Duane Morris LLP on 5/3/2012

Danger is lurking in the world of Internal Revenue Service audits, namely, parallel investigations. Parallel investigations by the IRS are simultaneous civil and criminal investigations of an individual or business entity,...more