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HTMLU.S. Tax Court: Value of Bank Reward Points is Taxable
John W. Mashni; Foster, Swift, Collins & Smith, P.C.;
Legal Alert/Article
December 1, 2014, previously published on November 20, 2014
With holiday travel season upon us, you may be thinking about redeeming some reward points you’ve earned from your bank for a free airline ticket. After a recent U.S. Tax Court ruling, the ticket may not be as free as you think.

 

HTMLMichigan Sales and Use Tax Audits
Nicholas M. Oertel; Foster, Swift, Collins & Smith, P.C.;
Legal Alert/Article
December 1, 2014, previously published on October 21, 2014
Every year, the Michigan Department of Treasury audits Michigan businesses for compliance with the Sales and Use tax laws. Oftentimes, those audits result in tax assessments that are disputed by the taxpayer. But, how does a taxpayer navigate the audit process and challenge a tax assessment?

 

HTMLIgnoring IRS Notice of Deficiency May Leave Taxpayer With No Recourse for Contesting Tax Liability
Jill Misener, David J. Moise; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 20, 2014
The US Tax Court recently held in Onyango v. Comm’r 142 T.C. 24 (2014) that a taxpayer could not contest a tax liability prior to making payment where the Internal Revenue Service (IRS) issued a valid Notice of Deficiency and the taxpayer failed to take advantage of previous opportunities to...

 

HTMLNew IRS Streamlined Filing Procedures Expands Eligibility to Us Residents and Foreign Residents
Shannon Smith Retzke; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 20, 2014
For the first time, the Internal Revenue Service (IRS) streamlined filing procedures are available to US resident taxpayers who have unreported foreign income or financial accounts. The new streamlined procedures also eliminate the risk assessment process associated with the old streamlined...

 

HTMLU.S. Supreme Court Will Hear ACA Subsidies Case
Mindi M. Johnson, Nicole E. Stratton; Foster, Swift, Collins & Smith, P.C.;
Legal Alert/Article
November 28, 2014, previously published on November 19, 2014
On Nov. 7, the U.S. Supreme Court decided it would hear a case concerning the health insurance subsidies provided to millions of Americans under the Patient Protection and Affordable Care Act. A June 2015 decision is expected in the case of King v. Burwell, which challenges the Internal Revenue...

 

HTMLCorporate Inversions: How US Shareholders May Be Adversely Affected
Maya Ladno; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 13, 2014
Due to a rapid rise in the number of transactions and the resulting potential losses for the US Department of Treasury, corporate inversions are a current hot topic in Washington. The US corporations which enter into these transactions defend their actions, at least in part, by highlighting their...

 

HTMLNew Inversion Notices Forthcoming
Sutherland Asbill Brennan LLP;
Legal Alert/Article
November 28, 2014, previously published on November 10, 2014
Our prior post on Notice 2014-52, Treasury’s crackdown on corporate inversions, outlined potential tools Treasury would consider using to counteract the attractiveness of inverting. The Treasury Office of International Tax Council announced that at least one additional notice will likely be...

 

HTMLTreasury Dropping Hints on Earnings Stripping
Sutherland Asbill Brennan LLP;
Legal Alert/Article
November 28, 2014, previously published on November 10, 2014
Treasury Department officials are stating publicly the potential methods it is considering to reduce the benefit of inversion transactions through so-called “earnings stripping.” According to reports of an October 29 panel discussion, Treasury is considering cutting back on interest...

 

HTMLSwitzerland Moves Toward Automatic Information Exchange
Paul L. Behling; Withers Bergman LLP;
Legal Alert/Article
November 28, 2014, previously published on November 20, 2014
Swiss Bank secrecy and data protection have been eroded by The Department of Justice investigations and the Foreign Account Tax Compliance Act (FATCA). Switzerland has now taken a formal move toward greater transparency.

 

HTMLMaryland Seeks Cash, Not Credit, Before Supreme Court
Sutherland Asbill Brennan LLP;
Legal Alert/Article
November 28, 2014, previously published on November 13, 2014
On Wednesday, November 12, 2014 the United States Supreme Court heard oral arguments in Comptroller of Maryland v. Wynne. The case turns on whether Maryland’s personal income tax system violates the dormant Commerce Clause of the United States Constitution because of Maryland’s failure...

 


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