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 March 11, 2025, the United States House of Representatives passed a joint resolution to overturn a rule that the IRS had promulgated regarding “Gross Proceeds Reporting by Brokers That Regularly Provide Services...more
In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...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 September 30, 2024, the Treasury Inspector General for Tax Administration (“TIGTA”) issued a report evaluating the IRS’s enforcement efforts relating to taxpayers with gambling and wagering winnings....more
In Varian Medical Systems, Inc. v. Commissioner, the Tax Court addressed a seeming oversight in the Tax Cuts and Jobs Act of 2017 (the “TCJA”) involving the effective dates for amendments to section 78 and the enactment of...more
The Treasury Department and Internal Revenue Service are proposing regulations that would make so-called basket contract transactions as listed transactions under section 6011(a) of the Internal Revenue Code....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
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
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 March 22, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued proposed rules for the collection and exchange of information on transactions involving crypto-assets. The OECD intends for these...more
On January 25, 2022, the Internal Revenue Services issued final regulations relating to the treatment of stock owned by domestic partnerships under certain provisions of subpart F of the Internal Revenue Code (“Subpart F”). ...more
Every few months or so seem to bring new revelations of a Ponzi scheme gone bust. In the aftermath, erstwhile investors often struggle to be made whole again. Fortunately, the federal income tax offers options to help,...more