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
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
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
6/27/2022
/ Administrative Appeals ,
Appeals ,
Article III ,
Income Taxes ,
Judicial Review ,
NPRM ,
Regulatory Flexibility Act ,
Reporting Requirements ,
Small Business ,
Standing ,
U.S. Treasury
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
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
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
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