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Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

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The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Revenue Procedure 2022-39 Continues Qualified Amended Return Treatment for Audit Disclosures, Adds Large Partnership

On November 16, 2022, the IRS released a long-awaited update to the procedure for large corporate taxpayers and large partnerships under continuous audit to obtain Qualified Amended Return (QAR) treatment for items disclosed...more

Morgan Lewis

Large Corporate Compliance and Data Analytics: Have You Analyzed Your Own Data Recently?

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The Internal Revenue Service will be implementing a new program using data analytics to select which large corporate taxpayers to audit. The program will identify which corporate tax returns show the highest compliance risk...more

K&L Gates LLP

Preparing for a Washington State Department of Revenue Audit

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The Washington State Department of Revenue (“DOR”) is the enforcement agency for the state sales, business and occupation (“B&O”), and other excise taxes. The DOR conducts routine excise tax audits through its Audit...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

Baker Donelson

Mississippi Court Rules Discriminatory Exclusion is Unconstitutional

Baker Donelson on

The Hinds County Chancery Court recently issued an opinion in AT&T Corp. v. Miss. Dep't of Revenue finding that Mississippi's dividend exclusion statute unlawfully discriminates against interstate commerce and is therefore...more

Butler Snow LLP

Hold The Phone! AT&T’s Constitutional Challenge To Mississippi’s Dividend Exclusion Statute Is Still Alive

Butler Snow LLP on

A Mississippi trial court has again found unconstitutional the state’s dividend exclusion statute, which disadvantages certain multistate taxpayers as compared to solely Mississippi taxpayers. This result comes from AT&T’s...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 5, Issue 11 - November 2014

Morrison & Foerster LLP on

In This Issue: - Court Orders Department of Finance to Release Corporate Tax Return Records to City Comptroller - ALJ Upholds State Tax Department Policy on Personal Liability of LLC Members for Sales Tax ...more

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