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Showing 1 - 7 of 203 results.
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Showing 1 - 7 of 203 results.
Pennsylvania, Philadelphia each clarify Sec. 163(j) guidance
Jun 24, 2019 | Alert
On April 29, 2019, the Pennsylvania Department of Revenue issued Corporation Tax Bulletin 2019-03, clarifying Pennsylvania’s treatment of the business interest expense limitation enacted under the Tax Cuts and Jobs Act (TCJA) pursuant to IRC Sec. 163(j).
Massachusetts court rules on excise tax apportionment
Jun 24, 2019 | Alert
Massachusetts Court of Appeals affirmed that subsidiaries of a cable and internet provider were not engaged in a national operation for tax purposes.
House tax package a major move on extenders, TCJA fixes
Jun 21, 2019 | Alert
Our Tax Legislative Update examines the House Ways and Means Committee package of tax bills passed June 20 that is expected to receive broad bipartisan support.
Temporary regs address Section 245A loophole
Jun 19, 2019 | Alert
The IRS has released temporary regulations (REG-106282-18) under Sections 245A and 954(c)(6) that limit gap-year and other planning strategies the IRS said used the dividends-received deduction (DRD) contrary to the legislative intent.
IRS releases final GILTI regulations
Jun 19, 2019 | Alert
The IRS released final (T.D. 9866) and proposed (REG-101828-19) regulations on June 14 addressing global intangible low-taxed income (GILTI), foreign tax credits, the treatment of domestic partnerships for purposes of determining Subpart F income of a partner, and a so-called “GILTI high-tax exclusion.”
Appellate court backs IRS in stock-based compensation case
Jun 18, 2019 | Alert
The 9th Circuit Court of Appeals has reversed the Tax Court in Altera Corp v. Commissioner (Nos. 17-70496, 16-70497), supporting the long-held IRS position that stock-based compensation (SBC) is an economic cost that must be included in the cost pools for cost-sharing purposes.
Congress sends IRS reform bill to president
Jun 14, 2019 | Alert
Congress sent the Taxpayer First Act — the IRS and tax admin reforms bill — to President Trump, who is expected to sign it into law. The law will update IRS technology, address cybersecurity and improve customer service and tax administration.