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The California FTB shared some of the most common tax audit issues for corporations today. Heading the list is the cost of performance and sourcing of intangible sales, along with sales factor and gross receipts, abusive tax shelters and credits. If you have questions...
California entrepreneurs were likely very surprised recently when they found out they were liable for paying four years' worth of taxes to the state that they were previously not required to pay. Last December, the Franchise Tax Board eliminated a capital gains tax...
There is currently a plethora of cases involving horse breeding or other horse related activities flooding the U.S. Tax Court. One such recent case, involved former San Francisco 49er linebacker Bill Romanowski. In the typical hobby loss case, the taxpayer puts a lot...
I've recently blogged about the plethora of multi-jurisdictional tax issues which continue to increase as business becomes ever more globalized. On February 20th, the U.S. Supreme Court yesterday heard oral argument in PPL Corp. v. Commissioner. In PPL, the Court is...
California and the other 49 states could soon collect millions of dollars from online sales taxes. Last week, Reuters News reported that U.S. House and Senate introduced the Marketplace Fairness Act of 2013 (The Bill). This is Indeed, a remarkable turn of events,...
Taxpayers in California and across the nation may have to wait a little longer for their tax refunds this year, in part because the IRS is trying to minimize the risk of identity theft. This has become a big problem in recent years, not only for the IRS, but for...
The U.S. crackdown on tax evasion continues. On February 14, 2013, the U.S. Treasury Department announced that Switzerland and the United States have signed an agreement to make Swiss banks disclose more information about U.S. account holders.The agreement is the...
In Pollard v. Commissioner TC Memo 2013-38, the U.S. Tax Court recently denied a taxpayers' deduction for the donation of a conservation easement where the taxpayer granted the easement pursuant to negotiations with a local zoning authority for approval of a...
Reuters is reporting that the current administration may soon ask Congress to require U.S. banks to disclose more information regarding foreign clients' account information. The Treasury's concentrated effort, on information-sharing, stems from the Foreign Account Tax...
A recent Tax Notes Today article by Contributing Legal Editor, Jeremiah Coder, warns that the Internal Revenue Service's (IRS) Offshore Voluntary Disclosure Program (OVDP) may have limits which could have dire consequences for taxpayers that continue to hold out. Mr....
