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The IRS Achievement: No One Gets Research Credits

A Treasury regulation provides that a researcher performing technological research for its customer is not entitled to federal income tax credits for the cost of the research if the researcher does not retain substantial...more

Disregarding Administrative Tax Guidance Aided the IRS in Two Cases and the Taxpayer in a Third Case

​​​​​​​Three courts - the Supreme Court, the Sixth Circuit, and the Tax Court - recently rejected administrative guidance in tax cases because the guidance was either wrong as applied, unnecessary, or inapplicable. The...more

The Status of the Pending Appeal in Silver v. Treasury Department

Key Takeaways - ..The pending case, Silver v. Internal Revenue Service, will provide insight, when decided, of the view of the Court of Appeals for the District of Columbia Circuit on the scope of judicial review of...more

IRS Expands COVID-19 Relief, Postpones Time for Performance of Certain Taxpayer-Favorable Acts

The Treasury Department and the IRS have expanded COVID-19 relief in Notice 2020-23 released April 9, 2020.  Taxpayers that have payment obligations and filing deadlines between April 1, 2020, and before July 15, 2020, may...more

Tax Day Moved to July 15

On March 18, 2020, the United States Treasury Department issued Notice 2020-17 to provide relief from tax deadlines because of the COVID-19 emergency. A taxpayer with a federal income tax payment due April 15, 2020, may...more

IRS Announces Updates to Income Tax Credits for Research Expenditures

The IRS Large Business and International Division ("LB&I") announced a campaign on February 27, 2020, to examine taxpayers' returns claiming income tax credits and deductions for research expenditures under IRC Sections 41...more

Right to Compute Tax Pursuant to Multistate Tax Compact Under Review in Michigan

Can a multistate corporation elect to use the Multistate Tax Compact’s apportionment reporting method in place of the Michigan Business Tax Act’s mandated formula without the Department of Treasury’s permission? The Michigan...more

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