Podcast - Betty: Glamour en pasarela, caos contable y tributario
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
How to Prepare for the IRS’s “New 90-Day Pre-Examination Compliance Pilot” Audit Process
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Examination
The U.S. Internal Revenue Service (IRS) appears to be entering a new and far more aggressive phase of enforcement focused on taxpayers claiming Puerto Rico residency and Act 60 (formerly Act 22) incentives or benefits. The...more
The General Assembly has recently proposed legislation to update Ohio’s Taxpayer Bill of Rights. House Bill 613 (H.B. 613) has been introduced but not yet assigned to a committee for review. The Bill offers several sweeping...more
The Ohio Board of Tax Appeals (Board) has found that chargebacks, i.e., above the line price reductions, are not discounts to the customer and should not be included in “gross receipts” for Commercial Activity Tax (CAT)...more
It’s not at all unusual to encounter the owner of a New York business who dreams about leaving the State. The reasons often given for the desired move include, among others, the cost of doing business in New York, the State’s...more
California residents seeking to change their residency status and avoid California tax must be prepared to substantiate their relocation. Simply moving to another state is not enough to relinquish California residency and tax...more
How might marrying a non-US citizen affect your taxes? What are some of the hidden issues that the IRS, California, and other state tax agencies may raise in an audit?...more
In a recent decision, the New York Tax Appeals Tribunal issued a sharp reminder to ‘snowbirds’ that changing domicile is about substance, not paperwork. In Matter of John J. Hoff & Kathleen Ocorr-Hoff, DTA No. 850209 (N.Y....more
Kilpatrick’s David Hughes recently spoke at the Institute for Professionals in Taxation (IPT) Sales Tax Symposium on “Proactive Sales Tax Strategies for Effective Risk Management and Compliance.” The session addressed...more
Did you know that the number of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and...more
Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more
With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more
Effective March 12, 2025, the Georgia Department of Revenue (“GADOR”) issued Policy Bulletin IT-2025-01 implementing various updates to its Mandatory Film Tax Credit Audit Program....more
Last Friday, New York’s Governor Hochul delivered the following remarks at the annual meeting of the Business Council of New York State:“Someone asked me today, are we going to raise income taxes? I said, ‘I’m not raising...more
As far back as I can remember, the end of August has always elicited a sense of dread comparable to what many schoolchildren, and a fair number of adults, experience every Sunday afternoon. In retrospect, I cannot say that...more
Both states and taxpayers have struggled with how to correctly source service receipts for apportionment purposes. The myriad of state sourcing provisions certainly do not add any clarity to the issue. Muddying the waters...more
Drawn from Steve Gorin’s 4th quarter 2023 newsletter, this course discusses preserving income tax benefits from estate tax audits and selected issues relating to S corporation sales and partnership redemptions....more
The Oregon Legislature, in House Bill 3373, created the Office of the Taxpayer Advocate within the Oregon Department of Revenue. The new law became effective on September 25, 2021. According to the Oregon Department of...more
The Multistate Tax Commission recently issued a policy position on not disclosing which states nominated a taxpayer for a joint audit or why they were nominated. Matt Hunsaker discusses....more
The Louisiana Department of Revenue (the Department) issued Revenue Information Bulletin No. 21-029 (the Bulletin), inviting corporate income taxpayers to resolve intercompany transfer pricing issues via the Louisiana...more
The New Jersey Tax Court held that the Division of Taxation (“Taxation”) cannot assess tax in years open under the statute of limitations if the tax is attributable to the elimination of net operating loss (“NOL”)...more
According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more
In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more
Throughout November, various Multistate Tax Commission committees held virtual annual meetings (due to COVID). In this episode, Matt Hunsaker runs down the highlights from each meeting, including technical corrections to...more
In our previous post, we explained the Ohio Department of Taxation proposed a regulation change to limit a taxpayer’s ability to make a retroactive consolidated filing election for Ohio Commercial Activity Tax purposes (CAT)....more
Many people are looking to move out of high tax jurisdictions - for a variety of tax and non-tax reasons. State tax officials audit residency changes with vigor. Betsy Smith joins Matt Hunsaker in the virtual studio to...more