The calendar year 2024 will bring multiple changes to the Texas franchise tax. Taxpayers responsible for entities operating in Texas should be aware of these rules as they plan for their filing and payment obligations in the...more
When the Inflation Reduction Act was passed last year, the legislation included massive funding increases for the Internal Revenue Service (IRS). The initial narratives regarding the funding increases focused primarily on...more
On May 4, 2023, Indiana Governor Eric Holcomb signed legislation (Laws 2023, SB419) that, among other tax changes, included provisions to exempt from income tax nonresidents receiving compensation for employment duties...more
Speaking at a Practicing Law Institute program on April 25, Internal Revenue Service (IRS) lawyer Clifford Warren indicated that the IRS has been using the anti-abuse rule of Treasury Regulation Section 1.701-2 to scrutinize...more
On October 5, 2022, the U.S. Department of the Treasury highlighted six separate notices requesting initial general public comments in response to specific sets of questions pertaining to climate and clean energy tax...more
The Repurchase of Corporate Stock provision of the Inflation Reduction Act of 2022 (IRA), often called the stock-buyback provision, imposes a one percent excise tax on the repurchase or redemption of stock by covered...more
The Inflation Reduction Act of 2022 (IRA) includes increased Internal Revenue Service (IRS) funding in the amount of approximately $80 billion over ten years. According to a Congressional Research Service report, the law...more
On May 18, 2022, in a 153-2 vote, the Massachusetts House of Representatives voted to amend the state’s tax code to provide income tax relief for Massachusetts cannabis businesses. ...more
On Monday, November 15, President Joseph Biden signed the $1.2 trillion Infrastructure Investment and Jobs Act (the Infrastructure Act). Although the legislation contains only a few tax provisions, one surprising change is...more
In 2021 the market for and interest in stablecoins—digital assets designed to maintain a stable value relative to a national currency—has skyrocketed, increasing over 500% with a market cap of approximately $130 billion. The...more
On Friday, November 5, the House of Representatives passed the Bipartisan Infrastructure Framework bill, formally known as the Infrastructure Investment and Jobs Act (the "Act"). Of particular note, the Act contains...more
On June 21, 2021, the U. S. Supreme Court declined to hear Eric D. Speidell, et al., Petitioners v. United States, which sought to overturn the Tenth Circuit Court of Appeals’ 2020 opinion on Speidell v. United States. In...more
On Friday, May 28, 2021, the Biden Administration released its Green Book setting out the President’s revenue and policy proposals. Of particular interest to investors is the administration’s proposal to raise the tax on...more
6/14/2021
/ Capital Gains ,
Estate Planning ,
Green Book ,
Income Taxes ,
Investors ,
Joe Biden ,
Long-Term Investment Funds ,
Personal Property Tax ,
Popular ,
Retroactive Taxes ,
Tax Rates ,
Transfer Taxes
On May 20, 2021, the Department of the Treasury released the American Families Plan tax compliance agenda, detailing the tax compliance initiatives in President Biden’s American Families Plan. The tax compliance agenda is...more
On May 17, 2021, the U.S. Tax Court issued a Memorandum Opinion in Vincent J. Fumo v. Commissioner, T.C. Memo. 2021-61, regarding the definition of a “disqualified person” under I.R.C. section 4958(a)(1). Managers of...more
On April 27, 2021, the United States Tax Court held that legal fees incurred by generic drug manufacturers in connection with “Section 271(e)(2)” patent infringement suits are deductible as ordinary business expenses and need...more
Pursuant to the CARES Act, many employers took advantage of the ability to defer payment of the employer portion of certain social security taxes that were otherwise due during 2020. Some have asked questions about whether...more
On March 27, 2020 the Coronavirus Aid, Relief and Economic Security Act (CARES) was signed into law. We have summarized below some of the more significant tax provisions in CARES applicable to businesses and individuals....more
On Friday March 20, 2020 the Internal Revenue Service issued IRS Notice 2020-18 regarding federal income tax payments and income tax returns due on April 15, 2020. The guidance supersedes and replaces IRS Notice 2020-17 that...more
In South Dakota v. Wayfair, Inc., et al., the U.S. Supreme Court recently overruled long-standing precedent on what is necessary to create “nexus” to collect sales or use tax on sales into a particular state. The decision...more
7/11/2018
/ Appeals ,
Commerce Clause ,
Constitutional Challenges ,
Internet Retailers ,
Interstate Commerce ,
Out-of-State Companies ,
Physical Presence Test ,
Quill ,
Reversal ,
Sales & Use Tax ,
SCOTUS ,
South Dakota v. Wayfair ,
Substantial Nexus