News & Analysis as of

Tax Liability

Pennsylvania Tax Amnesty Begins April 21, 2017

by Saul Ewing LLP on

The Pennsylvania Tax Amnesty Program begins on April 21, 2017, and continues through June 19, 2017. The amnesty period is open for 60 days. During the amnesty period, any taxpayer with existing tax liabilities owing to...more

Free Pass for Taxes Owed to Pennsylvania?

by Barley Snyder on

If you owe back taxes to Pennsylvania, you’re in luck. Starting April 21 and continuing to June 19, the Pennsylvania Tax Amnesty Program will waive all penalties and slash the interest rate on outstanding tax...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

China’s infamous shadow banking industry—an $8.5 trillion marketplace that’s sprung up in reaction to the government’s “campaign against financial leverage”—is back and bigger than ever these days....more

Partners Beware: New Audit Rules May Have a Big Impact on Your Bottom Line. Here’s What You Need to Know and How to Protect...

by Butler Snow LLP on

The arcane rules surrounding partnership audits rarely, if ever, come up, and most people don’t even know that they exist. What once was a set of rules confined to the dark recesses of the Internal Revenue Code are now...more

Capital Gains Tax decision in SCA

by Hogan Lovells on

On 28 March 2017, a judgment was handed down by the Supreme Court of Appeal (SCA) regarding capital gains tax owed by a taxpayer on the proceeds of a sale agreement from 2007 that was cancelled more than three years later....more

IRS Targets the Wealthy via Wealth Squad

IRS operates a Wealth Squad, which brings together teams of IRS specialists to coordinate the audit of wealthy taxpayers. IRS identifies wealthy “targets” with secret algorithms that are skewed against the wealthy. IRS also...more

For High-Income and International Taxpayers: Defensive Tax Planning

The Importance of Defensive Tax Planning - IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include...more

New Reporting Regime: Estates Who Have to File Federal Estate Tax Returns Need to be Aware of New Basis Consistency Law

by Bowditch & Dewey on

On July 31, 2015, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 introduced new tax law that affects executors who are required to file a federal estate tax return and beneficiaries...more

PA Tax Update: Amnesty Program and SUT Change

by Ballard Spahr LLP on

Pennsylvania has a tax amnesty program that will run from April 21, 2017, to June 19, 2017. Even with many limitations on participation, this program may provide value to eligible taxpayers who have unfiled Pennsylvania tax...more

Tax Preparation is NOT a Commodity

by Foodman CPAs & Advisors on

As we approach this year’s tax filing deadline of April 18th, do you think that you have your Tax Return under control? Before you answer yes, take the time to examine and evaluate who is preparing your taxes. Do they have...more

Michigan Treasury Issues Revised Interpretation of Unitary Business Groups Following LaBelle Decision

by Varnum LLP on

On February 28, 2017, the Michigan Department of Treasury issued guidance in response to the Supreme Court's denial of Treasury's application to appeal LaBelle Management, Inc v Michigan Department of Treasury, 315 Mich App...more

News from the Vermont Statehouse An - Analysis from DRM’s Government & Public Affairs Team - March 2017 #2

by Downs Rachlin Martin PLLC on

The House Ways and Means Committee is considering a proposal from the Vermont Department of Taxes to reduce the amount of use tax a person can pay without providing records to prove his or her tax liability. The rate would...more

A “Thriller” in Tax Court: The Estate of Michael Jackson and IRS Dispute Valuation of Pop Star’s Image

by Bowditch & Dewey on

How much were the late King of Pop’s name and image worth when he died? His estate put the figure at $2,105 but the IRS believes the value is at least $434 million. That’s a huge discrepancy and with penalties and interest...more

Top 10 Issues to Consider When Posting Workers in France

by Littler on

“Posting of workers,” a common practice within the European Union, refers to the assignment of an employee to work in another EU Member State (the "host country") on a temporary basis. Under this arrangement, also known as a...more

The Statute “Says What it Means and Means What it Says"

by Bryan Cave on

Trusts and Estates practitioners often focus solely on the Tax Code found in Title 26 of the United States Code and ignore other parts of the United States Code (U.S.C.). However, it is a mistake to do so as Marci McNicol...more

IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

Michael Jackson Estate Tax Case Moving Forward

by Charles (Chuck) Rubin on

Most estate tax practitioners will tell you estate tax it is all about valuation when assets are other than cash and marketable securities. The estate tax case of the Michael Jackson estate is an ideal demonstration. Tax...more

Correcting Tax Mistakes after Fairmont and Jean Coutu

by Dentons on

I was very glad to be a panelist for the Canadian Tax Foundation’s conference on the Supreme Court of Canada’s decisions in Fairmont and Jean Coutu. During the discussion the panelists were asked about the ways taxpayers...more

Ninth Circuit Reaffirms Lozano, Holds Typicality Does Not Require Identical Injuries Among Class Members

by Carlton Fields on

The Ninth Circuit recently affirmed orders by the District Court for the Northern District of California certifying two national classes in an action under Racketeer Influenced and Corrupt Organizations Act (RICO), the Fair...more

Watch out for Fraud in Family-Business Purchase Agreements

by Murtha Cullina on

In business purchase agreements, including agreements between family members, the seller often retains pre-sale liabilities, such as tax liabilities, while the buyer assumes post-closing liabilities related to the business’...more

IRA Owner Taxed on Distribution, Even Though Funds Were Improperly Rolled into IRA

by Charles (Chuck) Rubin on

A deceased husband's IRA was incorrectly rolled over into an IRA of his widow, instead of being paid to his estate. The widow then distributed funds from the IRA to her stepson....more

Shareholder Liability For Corporate Income Tax?

by Farrell Fritz, P.C. on

Limited Liability - In general, the creditors of a corporation cannot recover the corporation’s debts from its shareholders—the shareholders enjoy the benefit of limited liability protection as a matter of state law....more

Personal Liability of Executors for Tax Liabilities of the Estate Under the Federal Priority Statute, 31 U.S.C. 3713

This is an appeal of summary judgment by the personal representative (the “PR”) of an estate. The lower court found the PR to be personally liable under the federal priority statute, Section 3713, for tax liabilities due from...more

A Substitute for Estate Tax Closing Letters

by Pessin Katz Law, P.A. on

In Notice 2017-12 (the “Notice”) the IRS announced that an “account transcript” from the agency can substitute for an Estate Tax Closing Letter (“ETCL”)....more

Enforcement of Foreign Tax Claims

by Sanford Millar on

In many cases we have handled the taxpayers were dual nationals who have not only failed to adequately disclose and report foreign bank account and income to the IRS, but have also failed to report to the other country. This...more

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