Residence may seem to be a relatively simple thing to determine. It’s where you live, right? Well, leave it to the Internal Revenue Code to complicate this question. There are different tests for residency when it comes to...more
On January 14, 2025, the Treasury Department and IRS issued final and proposed regulations on sourcing income from digital content and cloud transactions.
Why is Source Important?
While U.S. persons generally are...more
Section 897 of the Internal Revenue Code provides that gain or loss of a nonresident alien or foreign corporation from the disposition of a United States real property interest is subject to U.S. federal income tax. And,...more
On May 8, 2024, the Treasury Department issued proposed regulations regarding the classification, taxation, and reporting of foreign trusts. The proposed regulations were issued for sections 643(i), 679, 6039F, 6048, and 6677...more
A recent Tax Court case illustrates the importance under current case law of thinking about the tax consequences of a potential verdict or settlement early on and attempting (if the facts allow) to establish a basis for...more
No gain or loss generally is recognized on a transfer of property to a partnership in exchange for an interest in that partnership for federal income tax purposes (note that “partnership” here includes a limited liability...more
In an “applicable asset acquisition,” the sale of the assets of a business may be subject to certain allocation and reporting requirements for federal income tax purposes. It’s essential for the seller and purchaser to be...more
Amplifying its efforts to crack down on U.S. taxpayers’ use of Malta pension funds to attempt to achieve federal income tax savings, the IRS recently has issued proposed regulations identifying these funds as listed...more
Hiya, folks and welcome back to a whole new edition (in a whole new year) of the Texas Tax Roundup! January started the year off with a blast! Let’s see what happened! Sales and Use Tax Governmental Exemption...more
The United States Virgin Islands (“USVI”) is an unincorporated territory of the United States.[1] But that doesn’t mean that they’re subject to exactly the same laws as in the United States—especially when it comes to taxes....more
December was a bit of a slow month on the Texas tax front. Hopefully everyone was out of their respective offices and enjoying the holidays/resting up for the upcoming legislative session. Still, we got an interesting opinion...more
Hey everybody! Welcome back to another for another edition of Texas Tax Roundup! Hope y’all had a happy Thanksgiving! We got some franchise tax apportionment, some sales and use tax in the oil and gas industry, and some...more
Are you U.S. citizen or resident? Have you ever just wanted to leave the whole U.S. federal tax system behind? Well, you can . . . try at least. But there’s a cost....more
Court Cases Sales and Use Tax Manufacturing Exemption Hegar v. Tex. Westmoreland Coal Co., Case 21-1007 (Tex. Sept. 30, 2022)—In this case, the Texas Supreme Court denied the Comptroller’s petition for review, leaving the...more
One of the more confusing areas of international tax law is determining when withholding is required.
Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more
Howdy folks, and welcome back to another action-packed edition of the Texas Tax Roundup! Let’s see what shocking developments in the realm of Texas tax that the month of August had in store!...more
10/5/2022
/ Administrative Law Judge (ALJ) ,
Exports ,
Franchise Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Sales Tax ,
State Taxes ,
Tax Liability ,
Tax Planning ,
Tax Returns
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation -
AN EXPERIENCE UNLIKE ANY OTHER -
Find yourself on the cutting-edge of international tax law, with...more
8/31/2022
/ Continuing Legal Education ,
Cross-Border ,
Cryptocurrency ,
Enforcement ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
Multinationals ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Reform ,
Transfer Pricing ,
Webinars
Bailey v. Drexel Furniture Co., 259 U.S. 20 (1922) (a/k/a “Child Labor Tax Case”) - Summary: In the Child Tax Labor Case, the U.S. Supreme Court ruled that a purported “tax” was really a “penalty” and therefore an...more
In Eisner v. Macomber, the U.S. Supreme Court ruled that for purposes of the Sixteenth Amendment, “income” was “a gain, a profit, something of exchangeable value proceeding from the property, severed from the capital however...more
Things have been heating up this summer. Let’s see what’s been cooking with the Texas Comptroller’s office....more
In Moore v. United States, the U.S. Ninth Circuit Court of Appeals recently rejected arguments that the mandatory repatriation tax imposed under section 965 of the Internal Revenue Code violated the Constitution’s...more
On June 7, 2022, a bill was introduced in the U.S. Senate that would provide greater clarity regarding the taxation and regulation of digital assets. Here are some of highlights....more
Howdy folks, and welcome back to another captivating installment of Texas Tax Roundup, where we gab about all things Texas taxes. Nothing court-side this month, just a bunch at the administrative level. Still, it’s...more
Howdy y’all! Has it been a month already? We’ve got another action-packed month of Comptroller-related news. Here we go! Court Cases Courts of Appeals Hegar v. Black, Mann, and Graham, L.L.P., No. 03-20-00391-CV (Tex....more
Huh whuh? . . . Well . . . Well, howdy! Nice, erm, um well . . . Nice to see ya’ll again at or near this nebulous home home on the range of Texas taxability! Welcome back to another tax-packed installment of all things Texas...more