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Income Taxes › Administrative Procedure Act

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Akin Gump Strauss Hauer & Feld LLP

DC Circuit Decision Opens Doors to Rate Increases by FERC-Regulated Oil, Liquids and Refined Products Pipelines

Akin Gump Strauss Hauer & Feld LLP on

Interstate oil, liquid and refined products pipelines regulated by the Federal Energy Regulatory Commission (FERC) will soon be able to raise their transportation rates (provided they were set using FERC’s popular Index rate...more

Pillsbury - SeeSalt Blog

California’s 2024-2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit...

Pillsbury - SeeSalt Blog on

The May Revision of California’s 2024-2025 state budget seeks to block refund claims, worth approximately $1.3 billion for historical tax years, and $200 million per year going forward, by codifying informal guidance recently...more

Pillsbury - SeeSalt Blog

California Trial Court Grants Industry Trade Association’s Motion for Summary Adjudication, Declaring Technical Advice Memorandum...

Pillsbury - SeeSalt Blog on

A California trial court granted summary adjudication in the American Catalog Mailers Association’s (ACMA) action against the Franchise Tax Board (FTB), invalidating FTB guidance that says certain online activities exceed the...more

McDermott Will & Emery

Weekly IRS Roundup December 26 – December 30, 2022

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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 26, 2022 – December 30, 2022...more

Polsinelli

The IRS is Not Backing Down: Proposed Regulations Issued Regarding Abusive Tax Shelters Including Certain Syndicated Conservation...

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Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more

Fox Rothschild LLP

Omnibus Bill Limits Conservation Easements, but the Long-Requested Safe-Harbor Does Not Apply to Current Cases

Fox Rothschild LLP on

On the morning of Dec. 20, 2022, we finally got a look at the language being negotiated in the 4,155 page Omnibus spending bill. Buried in the bill is new language relating to donations of conservation easements by...more

Polsinelli

Big Win for Investors Facing Listed Transaction Penalties for Conservation Easements

Polsinelli on

On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more

Miller Canfield

Does a Tax Cut Jobs Act Provision Decrease Income Taxes on Marijuana Businesses?

Miller Canfield on

Key Takeaways: ..A pending U.S. Tax Court case presents an interesting theory to preclude the federal income tax disallowance of all deductions of a marijuana business. ..The theory rests on a provision in the 2017 Tax...more

Freeman Law

Court Declares IRS Micro-Captive Notice 2016-66 Unlawful: What Taxpayers Should Do Now

Freeman Law on

Introduction.  On May 17, 2021, the United States Supreme Court handed the IRS a significant loss when it concluded that CIC Services, LLC (“CIC”) could continue its lawsuit against the IRS for violations of the...more

McDermott Will & Emery

District Court Vacates, Sets Aside IRS Reportable Transaction Notice

McDermott Will & Emery on

The fallout from taxpayer challenges to the Internal Revenue Service’s (IRS) “reportable transaction” regime continues. On March 21, 2022, the district court in CIC Servs., LLC v. IRS ruled in favor of the taxpayer, vacating...more

Sullivan & Worcester

A Warm Welcome to the Tax Trotter

Sullivan & Worcester on

Happy New Year and welcome to the Tax Trotter! What a year 2020 has been! Stock markets running high, travel low, Zoom reigning supreme with the blue light eyeglass filter becoming as popular as the anti-glare...more

Eversheds Sutherland (US) LLP

New California Tax Agencies’ Roles Clarified

Eversheds Sutherland (US) LLP on

On September 16, 2017, California Governor Jerry Brown signed Assembly Bill (A.B.) 131 into law, making various changes to the Taxpayer Transparency and Fairness Act of 2017 (Act) enacted on June 27, 2017. The Act overhauled...more

Allen Matkins

The Taxpayer Transparency And Fairness Act Is Anything But

Allen Matkins on

Recently, I wrote about the stealth with which the California legislature enacted AB 102, which it ironically named the Taxpayer Transparency and Fairness Act of 2017. Having been birthed in opacity, AB 102 will operate with...more

Bradley Arant Boult Cummings LLP

Mississippi Supreme Court Reverses Court of Appeals in Equifax Case

Bradley Arant Boult Cummings LLP on

In a landmark (and somewhat surprising) decision issued June 20, the Mississippi Supreme Court reversed the Mississippi Court of Appeals’ decision in Equifax, Inc. and Equifax Credit Info. Services, Inc. v. Miss. Dep’t of...more

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