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Appeals Business Taxes

Allen Barron, Inc.

What to do if You Receive an IRS Audit Notification Letter 0724

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What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

Dechert LLP

Upper Tribunal Affirms FTT Bluecrest Decision on LLP Salaried Member Rules

Dechert LLP on

Asset managers established as LLPs will welcome the Upper Tribunal’s recent decision to uphold the decision of the First Tier Tax Tribunal (“FTT”) on the application of the salaried member rules in Bluecrest...more

Freeman Law

The Appeals Process for Property Tax Appraisals

Freeman Law on

Property tax, or ad valorem tax, is a fact of life for people and businesses in Texas. As one of the few states in the United States without income tax, Texas counties rely on property tax as a source of revenue to pay for...more

Freeman Law

Court Strikes Down Largest Non-Willful FBAR Penalty Ever

Freeman Law on

I have previously written on the Bittner (E.D. Tex.) case in a prior Insight.  Briefly summarized, the taxpayer, Mr. Bittner, was a dual citizen of both Romania and the United States.  However, in 1990, he moved back to...more

BCLP

Court of Appeal Unim-Prest with Attempts to “Pierce the Veil” of Rating Mitigation Scheme

BCLP on

Empty property rates are a tax on failure; the failure of the owner to let premises or to find its own use for the premises. Given they are charged at the same rates as occupied property, it’s no wonder property owners seek...more

Buckingham, Doolittle & Burroughs, LLC

Ohio Supreme Court Rejects Taxes on Draft Beer Tap Maintenance and Cleaning

Ohio Supreme Court rejects taxes on draft beer tap maintenance and cleaning–limits scope of taxation on janitorial-type services....more

Buckingham, Doolittle & Burroughs, LLC

Ohio’s burdensome municipal income tax structure hinges on the meaning of “levy.”

The 10th District Court of Appeals has heard oral arguments to decide the fate of Ohio’s efforts to reform municipal income tax for businesses and enact a centralized filing system. Last year, Ohio enacted H.B. 49, which...more

Burns & Levinson LLP

In My Opinion: Alpenglow Botanicals v. United States

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If you read my most recent post on Section 280E of the Internal Revenue Code, you might have picked up on my disappointment with the Alpenglow opinion. Whether the conclusion is right or wrong, in my estimation, it could have...more

Bradley Arant Boult Cummings LLP

Impact of Check-the-Box Conformity on State Tax Appeal Procedures – Who’s the Real Taxpayer Here? - SALT Alert: Alabama Edition

In a case of first impression by an Alabama appellate court, the Alabama Court of Civil Appeals recently considered the appeal of the Alabama Department of Revenue (ADOR) of an adverse circuit court ruling involving whether...more

Bradley Arant Boult Cummings LLP

Recent Rulings on “Family Limited Liability Entity” Election Create Traps for the Unwary

Although every LLC, limited partnership or other pass-through entity doing business in Alabama, and even those simply organized under Alabama law, are subject to an annual business privilege tax (BPT), certain entities can...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Recent Court of Appeals Decision Provides Hope for Taxpayers Fighting for Congressionally Sanctioned Tax Benefits"

For the second time in just over a year, the U.S. Court of Appeals for the Sixth Circuit reversed the United States Tax Court and affirmed the right of a taxpayer to structure its affairs in a manner that takes into account...more

Perkins Coie

Washington Court of Appeals: No Transactional Nexus Requirement or Dissociation for Washington B&O Tax

Perkins Coie on

On April 29, 2015, the Washington Court of Appeals issued an important tax decision in Avnet, Inc. v. Washington Department of Revenue, Dkt. No. 45108-5-II. In its most significant holding, the court of appeals effectively...more

Lowndes

Should You Abandon An Underperforming Partnership?

Lowndes on

Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more

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