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United States

Free Articles from This Topic

This content is available without a Tax Notes subscription.

Tax Notes State

Garrett: States Could Apply MTC’s P.L. 86-272 Approach on Audit

9/27/2021

Instead of going through the legislative or regulatory process, states might simply apply on audit the Multistate Tax Commission’s interpretation of whether internet business activities are protected by P.L. 86-272, a prominent practitioner has cautioned.

Tax Notes International

Hollywood Film Investment Was Planned Sham, Canadian Court Rules

9/27/2021

Canada’s Federal Court of Appeal in Paletta v. The Queen upheld a decision by the Tax Court of Canada that film financing transactions between the appellant and 20th Century Fox Film Corp. were prearranged shams undertaken to evade tax.

Tax Notes International

A Systematic Approach to the Classification of Cryptocurrency

9/27/2021

Paul Carman examines the terms commodities, securities, money, and foreign currency in relation to the tax treatment of cryptocurrency, and he argues that they should be subject to consistent definition and usage throughout the IRC.

Tax Notes International

Jury Finds No Foul in Ex-NBA Player’s Career in China

9/27/2021

The defendant in United States v. Morris was acquitted on 11 counts of filing false tax returns and wire fraud related to his stint playing basketball in China.

Tax Notes International and Tax Notes Federal

Improvement Property, CARES Act NOL Regs Finalized Without Change

9/27/2021

The IRS has finalized without change proposed rules on calculating qualified business asset investment for qualified improvement property and transition rules on net operating losses related to coronavirus legislation.

Tax Notes International

LB&I Retires Its OVDP Withdrawals Campaign

9/27/2021

The IRS has retired its offshore voluntary disclosure program declines and withdrawals campaign, one of the first rolled out when the Large Business and International Division announced its new compliance measure nearly five years ago.

Tax Notes International

Globe-Trotting Consultant Claims Ignorance of Foreign Income Regs

9/27/2021

A well-traveled business consultant claims she wasn’t aware she had to pay tax for income earned outside of the United States, according to a Tax Court petition in Philipp v. Commissioner.

Tax Notes Federal

No Tax Documents for GoFundMe? The IRS Should Change That

9/27/2021

Ariel S. Greenblum highlights new and notable tax law developments in this week's issue of Tax Notes Federal.

Tax Notes Federal

House Dems Fear 1993 Redux on Tax Bill by Uncertain Senate

9/27/2021

Some taxwriting committee Democrats see the pause on the $3.5 trillion reconciliation bill as reminiscent of 1993, when House Democrats made the first move on a $1.5 trillion budget resolution to their later regret.

Tax Notes Federal

ABA Section of Taxation Meeting: Tax Bar May Be Left to Wonder on Reconciliation Bill’s Intent

9/27/2021

Congress’s top nonpartisan tax expert says it is unlikely that Senate committees will issue official reports describing the legislative intent behind their sections of the reconciliation bill, possibly hindering tax practitioners, federal officials, and courts in interpreting the massive bill if it ...

Tax Notes Federal

New Jersey Dems Insist SALT Must Be in Reconciliation Bill

9/27/2021

A pair of New Jersey Democrats who won election in 2018 on their party’s pledge to restore the state and local tax deduction said they don’t believe the $3.5 trillion budget reconciliation bill can pass without that promise finally being kept.

Tax Notes Federal

Meetings

9/27/2021

This week's Tax Calendar includes a list of all meetings, hearings, seminars, and conferences.

Tax Notes Federal

Investor Groups Ask IRS to Suspend E-File Rule for Foreign Filers

9/27/2021

Recently announced changes to the IRS’s electronic filing system may make proposed regulations to expand e-filing unworkable for some qualified intermediaries and foreign financial institutions, an IRS public hearing was told.

Tax Notes Federal

GOP State Treasurers Slam Biden's Bank Reporting Proposal

9/27/2021

A group of Republican state treasurers and financial officials has blasted a Biden administration proposal that would require banks to report citizens’ personal account information to the IRS, expressing doubt that the measure will help in collecting taxes from tax evaders.

Tax Notes Federal

In-Person Appeals Conferences Will Return Post-Pandemic

9/27/2021

The IRS is committed to returning to in-person Appeals conferences once operations return to normal following the pandemic, but the timeline remains unclear.

Tax Notes Today International and Tax Notes International and Tax Notes Today Global and BEPS Expert

Ways and Means Draft Would Redesign GILTI Pragmatically

9/27/2021

Mindy Herzfeld evaluates the compromises in the recent House Ways and Means Committee international tax proposal and their chances to become law.

Tax Notes Today International and Tax Notes International and Tax Notes Today Global

Ways and Means Bill Lobbyist Change: Less Subpart F, More Profit Shifting

9/27/2021

In a Letter to the Editor, Jeffery M. Kadet argues for the removal of subsections (a) and (b) of section 138129 from the recent House Ways and Means draft bill.

Tax Notes Today Federal

ABA Tax Section Offers Comments on Voluntary Disclosure Practice

9/27/2021

The American Bar Association Section of Taxation has submitted comments on the voluntary disclosure practice, including suggestions for making the information-gathering process less onerous for taxpayers and the IRS, ensuring that the program is applied fairly and equitably, and encouraging eligible...

Tax Notes Today Federal and Tax Notes Federal

Congress Considers Foreign-Controlled CFCs

9/27/2021

Lee A. Sheppard examines the House Ways and Means Committee bill that would restrict creation of new controlled foreign corporations and target inversion tactics that avoid subpart F income, pointing out the bill’s problems, including constitutionality concerns.

For your convenience, individual items published in multiple publications have been combined into one entry. The search results count represents each time an item was published.
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