News & Analysis as of

Tax Appeals

Offit Kurman

So, The IRS Has Selected Your Return for Audit

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The Internal Revenue Service (“IRS”) audits 1% to 2% of small business income tax returns annually for one of two reasons: (1) something about the return (or information reported on the return) flagged the return for a closer...more

Pullman & Comley - For What It May Be Worth

Your Board of Assessment Appeals Playbook: Forms, Data Support, and Timing

With the Connecticut Board of Assessment Appeals (BAA) appeal deadline fast approaching, less than 3 weeks remain (in most municipalities) to prepare and file your BAA appeal form. ...more

Blank Rome LLP

The BR State + Local Tax Spotlight: January 2026

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Welcome to the January 2026 edition of The BR State + Local Tax Spotlight. We know the importance of remaining up-to-date on State + Local Tax developments, which appear often and across numerous jurisdictions. ...more

Blank Rome LLP

Washington Court Denies B&O Tax Refund to IT Company in Apportionment Dispute

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In Valente Solutions, LLC v. Department of Revenue, the Washington Court of Appeals addressed whether an information technology consulting firm was entitled to a refund of Washington business and occupation (“B&O”) taxes for...more

Baker Donelson

Tennessee Department of Revenue Releases New Informal Conference Decision Summaries

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Summaries Released of Select Informal Conference Decisions: The Tennessee Department of Revenue (Department) recently posted certain selected informal conference summaries, which provide taxpayers with insight into how the...more

Greenbaum, Rowe, Smith & Davis LLP

What Commercial Property Owners & Taxpayers Should Know About Filing a New Jersey Property Tax Appeal in 2026

New Jersey taxpayers continue to face one of the highest real estate tax burdens in the nation. The state’s high tax rates, coupled with fears of an economic downturn, increased tenant vacancies and high interest rates, can...more

Pullman & Comley - For What It May Be Worth

March 1 Property Tax Appeal Deadline in New Hampshire

A New Hampshire property owner that believes its real property assessment is excessive or disproportionate has until March 1 to file an abatement application with the municipality in which its property is located.  ...more

Blank Rome LLP

Ohio BTA Rejects Commissioner’s Sourcing Method

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It is a foundational principle of statutory interpretation that statutes be read to give effect to their plain meaning. Where a statute is amended over time, as is often the case, it must be read so as to give effect to the...more

Keating Muething & Klekamp PLL

A Tax Win for Limited Partners

A recent federal court decision furnishes limited partners with a significant tax victory. The Fifth Circuit Court of Appeals recently decided that limited partners are eligible for the self-employment tax exclusion under...more

Cole Schotz

2026 Tax Appeal Alert

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As we begin the new year, it is time to evaluate whether your current property tax assessments accurately reflect the evolving market. While inflationary pressures persist and interest rates remain high, we are seeing a...more

Winstead PC

Fifth Circuit Rejects Tax Court’s Definition of “Limited Partner” for Self-Employment Tax Purposes

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The U.S. Court of Appeals for the Fifth Circuit ruled that the meaning of “limited partner” under Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”), is determined under state law. ...more

Seward & Kissel LLP

Sirius-ly? Another Self-Employment Tax Ruling!

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In the latest self-employment tax ruling, the Fifth Circuit Court of Appeals issued a ruling in Sirius Solutions, L.L.L.P. v. Commissioner (the “Ruling”) that will ultimately permit state-law limited partners to exclude their...more

Bradley Arant Boult Cummings LLP

Alabama DOR Issues Guidance Regarding New Postmark Procedures Impacting Time-Sensitive Filings

The Alabama Department of Revenue (“AL DOR”) published helpful guidance on January 28 regarding “recent updates to the United States Postal Service (“USPS”) procedures that may affect postmark dates on mailed tax returns,...more

Harris Beach Murtha

Reminder: Appeal Connecticut Real Property Tax Assessment by Feb. 20

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Property owners who wish to challenge their tax assessment believing that their property was overvalued on the Oct. 1, 2025, Grand List only have a couple of weeks left to file a written appeal with the Board of Assessment...more

Mayer Brown

Tax Reform: Complementary Law No. 227/2026

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On January 14, 2026, Complementary Law 227 (“CL 227/2026” or the “Complementary Law”) was published, containing the additional regulation of the Tax Reform on Consumption. In summary, L 227/2026 sets forth rules on the...more

Cole Schotz

Sirius Victory for Limited Partners

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On January 16, 2026, in Sirius Solutions v. Commissioner, the U.S. Court of Appeals for the Fifth Circuit held that limited partners in a partnership may qualify for an exemption from self-employment tax on their distributive...more

Proskauer - Tax Talks

Fifth Circuit in Sirius Solutions Reverses Tax Court and Exempts Limited Partners from Self-Employment Tax

Proskauer - Tax Talks on

On January 16, 2026, in Sirius Solutions, L.L.L.P. v. Commissioner, No. 24-60240 (5th Cir. Jan. 16, 2026), the U.S. Court of Appeals for the Fifth Circuit reversed the Tax Court and held that, for self-employment tax...more

Cadwalader, Wickersham & Taft LLP

VAT on Tour

In HMRC v Hotel La Tour Ltd [2025] UKSC 46 (“Hotel La Tour Ltd”), the UK Supreme Court considered whether a holding company was entitled to recover input Value Added Tax (“VAT”) on professional fees incurred in connection...more

Stinson LLP

Update on Limited Partner Exception to Self-Employment Tax Liability: Fifth Circuit Decision Revives the Issue

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In the summer of 2025, we issued an alert on this subject, U.S. Tax Court Issues Ruling on Self-Employment Tax Exception for Limited Partners (06.11.2025). The case discussed in that alert was the third of a series of...more

Womble Bond Dickinson

Arizona 2025 Tax Developments: A Year-End Review

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Beginning last January 1, 2025, Arizona property owners were no longer required to collect and remit city Transaction Privilege Tax (TPT) on residential rental income for long-term stays of 30 consecutive days or more....more

Adler Pollock & Sheehan P.C.

A Sirius Exception for Limited Partner Taxation

On January 16, 2026, the United States Court of Appeals for the Fifth Circuit issued a ruling defining the term “limited partner” as used in the Internal Revenue Code of 1986, as amended (the “Code”). The Court held that a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Fifth Circuit Rejects IRS’ ‘Passive Investor’ Test for Limited Partner Exception in Self-Employment Tax

On January 16, 2026, the U.S. Court of Appeals for the Fifth Circuit decisively rejected the IRS’ attempt to narrow the definition of “limited partner” for purposes of the self-employment tax exclusion under section...more

Troutman Pepper Locke

Fifth Circuit Overturns Tax Court, Ruling in Favor of the Taxpayer in Case Evaluating Standard for Limited Partner Exception to...

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The U.S. Court of Appeals for the Fifth Circuit issued a split (2-1) decision in favor of the taxpayer in Sirius Solutions, L.L.L.P. v. Commissioner on January 16, 2026, holding that the “limited partner exception” to...more

Morgan Lewis

Fifth Circuit Rejects ‘Passive Investor’ Test for Limited Partner Exception to Self-Employment Tax

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On January 16, 2026, the US Court of Appeals for the Fifth Circuit became the first federal appellate court to interpret the “limited partner” exception from self-employment tax under Section 1402(a)(13) of the Internal...more

Pullman & Comley - For What It May Be Worth

Don’t Leave Money on the Table: The Deadline to Appeal Your Connecticut Property Assessment is Around the Corner

If you disagree with your property tax assessment, the deadline to file a formal appeal with your local Board of Assessment Appeals (BAA) is fast approaching....more

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