Resources Archive
May 27, 2020
Texas Comptroller Prevails in a Texas Franchise Tax Sourcing Case involving Satellite-Radio Programming — But Taxpayers Could Also Benefit in Other Contexts...
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In a case with potentially broad implications, the Third Court of Appeals recently agreed with the Texas Comptroller that revenues received by a taxpayer from subscription-based satellite-radio programming could be sourced to the location of the subscribers for Texas franchise tax purposes rather than to where the programming actually occurred.
May 26, 2020
Update on IRS Voluntary Disclosures...
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In a previous blog post, we discussed how and when to make a voluntary disclosure to the IRS using the revised voluntary disclosure guidelines announced by the IRS in November 2018. In April 2020, the IRS quietly updated Form 14457, Voluntary Disclosure Practice Preclearance Request and Application and its instructions. The changes to the form and instructions answer some of the outstanding questions but also raise new questions. For example, while the instructions clearly state that a disclosure will not guarantee immunity from prosecution, they also state multiple times that the practice provides a way to "avoid potential criminal prosecution."
May 26, 2020
2020 Metroplex Practice Management Group (MPMG)... [ read ]
May 20, 2020
Congratulations to Chuck Meadows, Joel Crouch, Josh Ungerman, Charles Pulman, Jeff Glassman and Jana Simons for being named to D Magazine's 2020 Best Lawyers....
May 20, 2020
Congratulations to Jeff Glassman and Cari LaSala for being named to Super Lawyers Texas 2020 Rising Stars....
May 20, 2020
The Texas Supreme Court Holds that the Sale of Military Aircraft to the U.S. Government for Foreign Buyers Could not be Sourced to Texas for Franchise Tax Purposes...
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In a recent decision involving the apportionment factor for Texas franchise tax purposes, the Texas Supreme Court held that the sale of certain military aircraft to the U.S. Government for ultimate delivery to foreign buyers could not be sourced to Texas, even though legal title and possession transferred in Texas, where the U.S. Government's involvement was statutorily required under federal law. In so holding, the Court disclaimed deciding whether tangible personal property must be sold to a buyer located in Texas or simply delivered to a point in Texas before the sale can be sourced to Texas. See Lockheed Martin Corp. v. Hegar, 2020 WL 2089741 (Tex. 2020). As discussed below, the decision is potentially significant both with respect to what it holds and also what it expressly disclaims to hold.
May 12, 2020
Meadows Collier was a proud sponsor of The Communities Foundation of Texas' Virtual Professional Seminar on May 12, 2020....
May 8, 2020
Debt Relief: Breaking Down the Tax Aspects of Covid-19's Economic Impact – Part I....
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This is the first in a series of blogs which will address various tax aspects of loan modification, debt relief, restructuring, bankruptcy, and other topics that will likely be at the forefront of the legal landscape in the near future as a result of Covid-19. The posts in this series, while not exhaustive of all topics, will provide guidance on important practice points and raise several issues taxpayers and practitioners should be aware of. The first topic in the series, cancellation of indebtedness, illustrates the often-unexpected tax consequences accompanying relief from indebtedness.
May 4, 2020
TXCPA Dallas Convergence 2020... [ read ]
May 1, 2020
EXPENSES PAID WITH FORGIVEN PAYMENT PROTECTION PLAN (PPP) LOAN PROCEEDS ARE NOT DEDUCTIBLE...
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The CARES ACT added the Paycheck Protection Plan program, which provides for a loan on favorable terms to qualifying small businesses to pay permitted expenses. These expenses are limited to payroll costs, mortgage interest, rent and utilities --all as defined in the statute and in SBA Guidance and FAQs.
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