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Income Taxes › Internal Revenue Service › Treasury Regulations

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Freeman Law

Tax Court in Brief | Scheizer v. Comm’r | Charitable Contribution Substantiation and Reliance on Tax Professional

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Tax Litigation:  The Week of October 3rd, 2022, through October 7th, 2022 Sander v. Comm’r, T.C. Memo. 2022-103 | October 6, 2022 | Morrison, J. | Dkt. No. 22472-16...more

Freeman Law

Tax Court in Brief | Medtronic, Inc. v. Comm’r | Section 482, Comparable Uncontrolled Transaction, Comparable Profits Method

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Tax Litigation:  The Week of August 15th, 2022, through August 19th, 2022 Medtronic, Inc. v. Comm’r, T.C. Memo. 2022-84 | August 18, 2022 | Kerrigan, J. | Dkt. No. 6944-11. Short Summary: This opinion regards a transfer...more

Freeman Law

Tax Treaties and Exempt Income

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Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers....more

Freeman Law

Joint Committee on Taxation Report on Tax Treatment of Charitable Contributions

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Joint Committee on Taxation Report on Tax Treatment of Charitable Contributions - On March 11, 2022, the Joint Committee on Taxation published its 49-page report (the “Report”) relating to the federal tax treatment of...more

Freeman Law

IRS Issues Guidance on Self-Dealing Rules for Private Foundations

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IRS Issues Guidance on Self-Dealing Rules for Private Foundations - On March 1, 2022, the IRS published its 128-page Exempt Organizations Technical Guide TG 58 Excise Taxes on Self-Dealing under IRC 4941. While not...more

Freeman Law

Federal Income Tax Characterization of Transactions Involving Computer Programs

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The sale of a computer program—it seems simple. But, as illustrated by the Treasury Regulations’ computer program characterization rules, the issue of just what a sale of computer program is can become confusing fast....more

Snell & Wilmer

What’s in the Cloud? Proposed IRS Rules for Digital and Cloud Transactions

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The long wait is over – the Internal Revenue Service (IRS) has finally issued proposed regulations (the Cloud Regulations) addressing the tax treatment of cloud transactions. Until now, there was no guidance specifically...more

McDermott Will & Emery

Treasury and the IRS Release Final Foreign Tax Credit Regulations

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Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more

McDermott Will & Emery

Final and Proposed BEAT Regulations Provide Some Relief

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Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more

A&O Shearman

Final and Proposed TCJA Foreign Tax Credit Regulations Create Traps and Opportunities

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On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more

McDermott Will & Emery

Weekly IRS Roundup August 26 – 30, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26 – 30, 2019. August 26, 2019: The IRS released a Treasury Decision in which it issued...more

McDermott Will & Emery

Weekly IRS Roundup July 8 – 12, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 8 – 12, 2019. July 9, 2019: The IRS updated its frequently asked questions page for the...more

Holland & Hart LLP

Understanding the Child Care Contribution Tax Credit

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The Child Care Contribution Tax Credit (the “CCTC”) provides a valuable tax credit against a taxpayer’s Colorado state income tax. The credit equals 50% of the amount of a contribution made to a qualifying Colorado charitable...more

Mitchell, Williams, Selig, Gates & Woodyard,...

The Case Against Do-It-Yourself Tax Returns: You Don't Know What You Don't Know

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In an effort to comply with the increasing complexity of the Internal Revenue Code (the “Code”) and the regulations promulgated thereunder, many taxpayers are looking to tax preparation software for assistance in preparing...more

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