Now that the New York State legislature has ended its session, we can examine one piece of legislation that changed the landscape for tax appeals challenging the assessment by the
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Supreme Court Affirms IRS Power to Summons Bank Information Without Notice to Delinquent Taxpayer
In Polselli v. IRS, the Supreme Court was tasked with determining whether the IRS, pursuant to powers granted in Internal Revenue Code (IRC) section 7609(c)(2)(D)(i), is entitled to issue third-party summonses, without notice, for bank account records in which the taxpayer targeted by the summons does not have a legal interest.
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California Court of Appeal Landmark Opinion Expands Intangible Asset Exemption from Property Tax Assessment
On April 7, 2023, the Second District of the California Court of Appeal published a landmark opinion on California property tax law that expands the tax-exempt status of intangible assets
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Washington Introduces Business & Occupation – Margins Tax Swap Bill
Since 2017, the Washington Tax Structure Work Group (TSWG) has been tasked with reviewing Washington’s tax structure. The primary goal of TSWG’s review was to identify ways to make “Washington’s
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IRS Temporary Relief for Foreign Financial Institutions Required to Report U.S. Taxpayer Identification Numbers Under FATCA: Potential Implications for ‘Accidental Americans’
IRS Notice 2023-11 provides temporary relief for foreign financial institutions to provide U.S. taxpayer identification numbers for preexisting accounts.
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Responding to Recent Taxpayer Victories, IRS Issues Proposed Regulations Identifying Syndicated Conservation Easement Transactions as Listed Transactions
The proposed regulations demonstrate that the IRS is taking a proactive approach in addressing the APA challenges to its method for identifying listed transactions. The IRS makes clear that it will continue to aggressively pursue syndicated conservation easement transactions.
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Treasury Announces Initial Guidance on the Inflation Reduction Act’s Labor Requirements for Renewable Energy Tax Credits and Incentives
The U.S. Department of the Treasury announced initial wage and apprenticeship guidance under the Inflation Reduction Act of 2022 (IRA) that applies to taxpayers in order to increase available credit
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U.S. Tax Court Invalidates Conservation Easement Notice, Abates Reportable Transaction Penalty for Failure to Comply with Administrative Procedure Act
In Green Valley Investors, LLC, Et Al., Bobby A. Branch, Tax Matters Partner, v. Commissioner, the Tax Court on Nov. 9 abated Internal Revenue Code (I.R.C.) § 6662A penalties
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U.S. Treasury Announces $5 Billion Allocation of New Markets Tax Credit Awards
The U.S. Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) on Oct. 28 announced $5 billion in New Markets Tax Credit (NMTC) awards with the goal of
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Sales Tax Ripples from the Keystone State to the Golden State – Impact of Pennsylvania’s Online Merchants Guild Decision on California Sales Tax
The Commonwealth Court of Pennsylvania recently held in Online Merchants Guild v. Hassell that the Pennsylvania Department of Revenue failed to provide sufficient evidence that non-Pennsylvania businesses selling merchandise through