News & Analysis as of

Tax Liability

IRS Can Pursue “Responsible Persons” for Unpaid Trust Fund Taxes and Automatic Stay Cannot Be Used to Enjoin Collection Against...

The Puerto Rico Bankruptcy Court followed the Third Circuit in holding that the Anti-Injunction Act, which prohibits suits to restrain the assessment or collection of any tax, is not superseded by section 105(a) of the...more

Self-Employment Tax, LLCs, & The “Limited Partner” Exclusion

by Farrell Fritz, P.C. on

In general, self-employed individuals are subject to employment taxes on their net earnings. The wages paid to individuals who are non-owner-employees of a business are also subject to employment taxes, regardless of how...more

US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

by Hogan Lovells on

Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from...more

Buying a company in business rescue that has assessed tax losses

by Hogan Lovells on

Companies in business rescue often have built-up assessed losses for tax purposes. Competitors wishing to take over the business of the company in business rescue would often view such assessed loss as a valuable asset, in...more

What Do You Do If You Receive A Notice From The IRS That Your Tax Return Is Under Audit?

by Dickinson Wright on

Depending on the amount that may be at issue, call a tax lawyer immediately. A tax lawyer that has handled audits before is able to provide important strategy and structure to the audit that will present your case in the...more

Tax court finds self-employment tax for active LLC member

by Thompson Coburn LLP on

Self-employment (SE) tax is one of the driving forces when a tax advisor recommends what type of entity to use for one’s business. My previous post, “Tax court finds no self-employment tax for passive LLC member,” described...more

California FTB Provides Guidance on Certain Section 382 Calculations - Tax Update Volume 2017, Issue 3

by Pepper Hamilton LLP on

California requires taxpayers that have income within and outside the state to "apportion" their overall income between the two categories based upon certain factors and rules for determining their California tax liability....more

German tax treatment of royalties regarding software license and database licenses – Draft guidance of German Federal Ministry of...

by Hogan Lovells on

Yesterday the German Federal Ministry of Finance (Bundesfinanzministerium) released a draft circular on the German tax treatment of royalties paid for software and database licenses granted by non-resident licensors....more

Taxpayer Tips: Best Practices for U. S. Tax Court

Taxpayers contesting IRS assessments of additional taxes, penalties and interest have a number of different options to contest and appeal those assessments. One of those options includes bringing a case to the United States...more

Energy Transfer, Williams, and the Circular Ownership of Stock

It is unheard of for a deal to die at the closing table because lawyers cannot deliver a required opinion regarding a transaction that they structured and negotiated. Yet, this is exactly what happened last year when two...more

Taking stock

by Hogan Lovells on

In a recently published judgment handed down by the Supreme Court of Appeal, the court had to consider the interplay between the accrual of income and the ability to claim a deduction in circumstances where trading stock was...more

La definizione agevolata delle controversie tributarie

L'articolo 11 del d.l. n. 50 del 24 aprile 2017, pubblicato in GU 24 aprile 2017, introduce e disciplina la c.d. "Definizione agevolata delle controversie tributarie". Please see full Publication below for more...more

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

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