In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more
A tax case pending in the United States Supreme Court, Moore v. United States, may cause a cataclysmic change in the federal income tax. The 16th Amendment to the United States Constitution empowers Congress to impose “taxes...more
On August 9, 2023, the New York State Department of Taxation and Finance (Department) released 417 pages of proposed regulations, an important step toward concluding a now almost decade-long process to implement corporate tax...more
The U.S. tax system developed in response to colonial opposition to taxation without representation. As such, Article I of the Constitution provides that Congress may not impose a “direct tax” unless the tax is “apportioned”...more
The Indiana Tax Court held that a “pharmacy benefit management company” sold services as opposed to tangible personal property for tax years 2011 through 2013. The company’s receipts were properly sourced as revenue from...more
On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more
The first order of business for many state tax authorities in response to COVID-19 was deciding whether to extend their respective income tax filing and payment deadlines for the 2019 tax year, either automatically by...more
As a general rule, in accordance with IRC § 162(a), taxpayers are allowed to deduct, for federal income tax purposes, all of the ordinary and necessary expenses they paid or incurred during the taxable year in carrying on a...more
Governor Jerry Brown signed Assembly Bill 154 on September 30, 2015, updating California’s general conformity to the Internal Revenue Code and providing three new exceptions to the imposition of the Large Corporate...more
The IRS issued cross-border interest apportionment final regulations. These adopt the approach from the 2012 temporary regulations, requiring a 10% corporate partner to apportion its interest expense by reference to the...more