Viewpoints: Portfolio Company Pension Liabilities
How Might Your Company be Affected by West Virginia's Employment Law Changes?
As a general rule, when a married couple files a joint tax return, they are jointly and severally liable for the entire tax. But what happens if one spouse failed to report income and the other spouse did not know or have...more
Tax Litigation: The Week of July 18th, 2022, through July 22nd, 2022 Pettennude v. Comm’r, T.C. Memo. 2022-79 | July 18, 2022 | Buch, J. | Dkt. No. 636-21L Gonzalez v. Comm’r, T.C. Summary Opinion 2022-13 | July 18, 2022 |...more
Tax Litigation: The Week of June 6th, 2022, through June 10th, 2022 Musselwhite v. Commissioner, T.C. Memo. 2022-57 | June 8, 2022 | Ashford, J.| Dkt. No. 14380-16 Spencer v Commissioner, T.C. Memo. 2022-8 | June 7, 2022 |...more
Tax Litigation: The Week of May 2nd, 2022, through May 6th, 2022 DelPonte v. Comm’r, 158 T.C. No. 7 | May 5, 2022 | Holmes, J. | Dkt. Nos. 1144-05, 1334-06, 20679-09, 20680-09, 20681-09 Mighty v. Comm’r, TC Memo. 2022-44|...more
A taxpayer may request innocent spouse relief from the Internal Revenue Service (“IRS”) in the form of equitable relief—I.R.C. § 6015(f). Among its threshold conditions, Section 6015(f) generally requires an evaluation of...more
In the recent case of Todisco v. Commissioner of Internal Revenue, the Tax Court granted innocent spouse relief to the taxpayer, finding that it would be inequitable to hold her liable for the taxes at issue. As a result,...more
Tax Court Litigation: The Week of September 13 – September 17, 2021 - Donna M. Sutherland v. Comm’r, No. 3634-18, T.C. Memo 2021-110 | September 16, 2021 | Lauber | Dkt. No. 3634-18 - Short Summary: This is an...more
One of the most important decisions a board determines is what constitutes reasonable compensation. The rules for this determination are robust and so are the taxes imposed for violations of the Internal Revenue Code and the...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of February 22 – February 26, 2021 - Llanos v. Commissioner...more
During the course of 2020, the U.K. government has pushed ahead with introducing new measures that are likely to be of material relevance to financial restructurings and corporate reorganizations. There have also been other...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of October 31 – November 6, 2020 - Glade Creek Partners,...more
Soon after being elected, New Jersey’s Governor created a task force to end misclassification of independent contractors, and the state’s Department of Labor and Workforce Development (DOL) began increasing audits and its...more
Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise...more
Online marketplace operators should ensure compliance with UK rules that may cause them to be jointly and severally liable for UK value added tax on sales made by foreign traders on their marketplace....more
The Situation: Currently, married taxpayers can file joint federal income tax returns but file separate Illinois income tax returns if one spouse is not a resident of Illinois. The Development: New legislation would...more
The IRS has released new informal guidance (“Questions and Answers”) regarding section 965, containing information on making successive installment payments, filing transfer agreements as a result of certain acceleration or...more
On September 22, Governor Brown signed SB 1402, a bill that establishes joint and several liability for customers who contract with or use port drayage motor carriers who have unpaid wage, tax and workers’ compensation...more
The Bipartisan Budget Act of 2015, signed into law on November 2, 2015, has significantly changed the partnership tax audit rules, effective for tax years beginning after December 31, 2017. Under the current partnership...more