On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more
3/13/2025
/ Appeals ,
Chevron Deference ,
Corporate Taxes ,
FedEx ,
Foreign Tax Credits ,
Government Agencies ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Offsets ,
Regulatory Requirements ,
SCOTUS ,
Statutory Authority ,
Tax Avoidance ,
Tax Credits ,
Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025.
TAX CONTROVERSY-RELATED DEVELOPMENTS -
January 15, 2025: The US...more
2/5/2025
/ Appeals ,
Clean Energy ,
Corporate Taxes ,
Dispute Resolution ,
Final Rules ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Renewable Energy ,
Revenue Procedures ,
Tax Credits ,
Tax Planning ,
Tax Reform ,
Tax Returns
On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more
10/24/2023
/ Corporate Counsel ,
Corporate Taxes ,
Foreign Corporations ,
High Net-Worth ,
Income Taxes ,
Individual Retirement Account (IRA) ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Audits ,
Tax Incentives