Resources Archive
January 3, 2018
Tax Court Determines that IRS Must Obtain Written Penalty Approval under I.R.C. Section 6751(b) to Assert Penalties against Taxpayers....
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On December 20, the Tax Court issued a supplemental opinion in Graev v. Commissioner, in which it reversed its prior position on I.R.C. Section 6751(b) and agreed with the Second Circuit's decision in Chai v. Commissioner. In Chai, the Second Circuit held that Section 6751(b)(1) requires the IRS to obtain written supervisory approval of an initial penalty determination no later than the date the IRS issues the notice of deficiency or files an answer asserting the penalty. A previous blog post discussed the Chai decision and its impact on pending Tax Court cases.
December 27, 2017
Taxpayers May Want to Consider Accelerating Large Dollar Purchases Under the New Tax Law...
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As the year comes to a close, one additional matter that individual taxpayers may want to consider is whether to expedite any large dollar purchases into this year if sales tax will be due on those transactions.
December 22, 2017
Recent Tax Legislation Includes Significant Changes to the Taxation of "Qualified Equity Grants", While Possibly Signaling Other Deferred Compensation Reforms to Come...
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The House of Representatives and the Senate have been busy these past few weeks in their attempt to drag some semblance of H.R. 1, also known as the Tax Cuts and Jobs Act ("TCJA"), over the proverbial goal line, and it appears that they have done so this week. Barring any additional procedural snafus, the TCJA should land on President Trump's desk for his signature before the break for the holidays. While there hasn't been much publicity surrounding the possible changes to non-qualified deferred compensation plans, employers of privately held companies should pay particular attention to the end result of the TCJA as passed in its final form.
December 22, 2017
The Texas Comptroller Receives Christmas Gift from the Texas Supreme Court in MTC Apportionment Decision...
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In a much anticipated decision the Texas Supreme Court today issued its decision in Graphic Packaging Corp. v. Hegar, No. 15-0669, (December 22, 2017). The Court held that Graphic Packaging could not use the three-factor apportionment formula provided for in the Multistate-Tax Compact for apportioning Texas franchise tax, notwithstanding that Texas is a member of the Compact.
December 21, 2017
Estate Tax and the New Tax Act...
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As we sit on the precipice of the new tax act going into effect (it only needs the President's signature to become law), it appears that the only transfer tax change in the Act consists of the doubling of the Section 2010(c) basic exclusion amount from $5,000,000 to $10,000,000 for transfers made and decedents dying after December 31, 2017 and before January 1, 2026.
December 8, 2017
TSCPA CPE Expo- Houston... [ read ]
December 8, 2017
Louisiana Tax Conference... [ read ]
December 7, 2017
2017 TSCPA CPE Expo- Houston... [ read ]
December 7, 2017
Ensuring Success 2017 Live Streaming Conference... [ read ]
December 7, 2017
ABA 34th Annual National Institute on Criminal Tax Fraud... [ read ]
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