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Corporate Taxes Tax Penalties

Holland & Knight LLP

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

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In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

McDermott Will & Emery

Weekly IRS Roundup June 5 – June 9, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more

Eversheds Sutherland (US) LLP

Relief from the heat: IRS provides penalty waiver for taxpayers not considering CAMT liability in 2023 estimated tax payments

On June 7, 2023, the IRS released Notice 2023-42 (the Notice), providing taxpayers relief from the addition to tax under Section 6655 in connection with the application of the new corporate alternative minimum tax (CAMT). In...more

Miller Nash LLP

Today in Tax: How to Reduce Transfer Pricing Risks and Tax Penalties in Transactions with Overseas Affiliates

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Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposal on Domestic Businesses

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On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more

Freeman Law

Clarifying the Contours of “Reasonable Compensation”

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The law has always favored the term “reasonable.”  For example, the law affords protection against a negligence lawsuit if a person can demonstrate he or she acted as a reasonable person would have under similar...more

Foster Garvey PC

Curiosity Killed the Cat – Unfortunately the Oregon Legislature’s Curiosity Has Not Gone That Far With Respect to Our CAT: The...

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During the special session, the Oregon legislature passed House Bill 4202 (“HB 4202”), which Governor Kate Brown signed into law on June 30, 2020. The legislation, which makes several technical and policy changes to the...more

Dentons

Pay Your Taxes On Time - New Tax Laws Change Penalties

Dentons on

The Iowa Legislature’s passage of HF2641 makes several changes to Iowa tax law. Among these changes are updates to the Department of Revenue’s penalties....more

Foster Garvey PC

The Oregon Department of Revenue Formalizes Guidance on Estimated Tax Penalties Under the Oregon Corporate Activity Tax

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In a new temporary rule, the Oregon Department of Revenue (“DOR”) formalized its prior informal guidance relative to the assessment of penalties for failing to make sufficient estimated payments under Oregon’s Corporate...more

Foster Garvey PC

The CAT Still Has Sharp Teeth, but the Oregon Department of Revenue Has Temporarily Dulled Them a Bit

Foster Garvey PC on

As previously reported, the new Oregon Corporate Activity Tax (the “CAT”) went into effect on January 1, 2020. The new law is quite complex and arguably not very well thought out by lawmakers. Although the Oregon Department...more

Williams Mullen

Virginia Announces Payment Extension and Penalty Waiver for Corporate and Individual Income...

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In response to disruptions to Virginia taxpayers caused by the COVID-19 crisis, the Virginia Department of Taxation (the “Department”) has extended the deadline for Virginia taxpayers to pay their income taxes. This relief...more

McDermott Will & Emery

Weekly IRS Roundup December 2 – 6, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 2 – 6, 2019. December 2, 2019: The IRS issued final regulations providing guidance...more

Foster Garvey PC

School is Back in Session and the CAT is Among the Most Popular Courses

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What We Learned from one of the Oregon Department of Revenue’s Town Hall Meetings - Over the past few months, we have written extensively on the blog about Oregon’s new Corporate Activity Tax (the “CAT”). As announced in...more

McDermott Will & Emery

Weekly IRS Roundup September 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9 – 13, 2019. September 9, 2019: The IRS released a revision to its Internal Revenue...more

Pullman & Comley, LLC

Waiver Of Penalties And Interest In Connection With 2018 Pass-Through Entity Tax

Pullman & Comley, LLC on

In the Spring of 2018, the Connecticut Legislature adopted a Pass-Through Entity Tax (the “PE Tax”), which imposes a 6.99% tax on pass-through entities (partnerships, limited liability companies and S-corporations). The PE...more

Rosenberg Martin Greenberg LLP

What are some of the monetary penalties and other consequences of failing to properly report my foreign real estate and other...

Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated.  Each of these has its own corresponding penalties and generally applies to United States...more

Butler Snow LLP

Non-US Persons Holding US Real Estate: Penalties For Failing To File Certain IRS Forms Are Increasing To $25,000

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Most non-US persons who are properly advised regarding US real estate ownership will structure their holdings to include some combination of US LLCs, non-US companies, non-US partnerships, non-US trusts and/or non-US...more

Rosenberg Martin Greenberg LLP

The Maryland Comptroller is auditing my business regarding sales and use tax reporting. Can I be held personally liable for those...

Yes. If the Comptroller finds your business liable for sales and use tax, then you could be held personally liable for the tax, interest, and penalties assessed. Maryland law extends personal liability for sales and use tax...more

Holland & Knight LLP

Posible Amnistía Fiscal en México para 2019

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El anteproyecto de la Ley de Ingresos de la Federación para el ejercicio 2019 (LIF), contemplaría la condonación total o parcial de ciertos créditos fiscales sobre contribuciones federales y sus accesorios, el perdón de hasta...more

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Transportation, Ports and Maritime Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Burr & Forman

The IRS Has a Lien Against Me: What Do You Do? Tax Lien Release and Discharge (Part 6)

Burr & Forman on

Where an individual or business owes IRS taxes, Congress has given the IRS a tax lien against all the assets of the taxpayer. The lien covers real estate, homes, furniture, cars, investments, and nearly everything an...more

Burr & Forman

Tax Payment Plans: What Do You Do? (Part 3)

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If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can “seller-finance” and offer a payment plan with the taxpayer. The primary benefit of a payment plan is that...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 9

Appellate Division Holds That NYS Tax Department Properly Withheld Documents Requested Under FOIL - In a unanimous decision, the Appellate Division affirmed a decision of the Supreme Court, Albany County, which had...more

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