On March 16, 2023, California Assembly Bill 52 (AB 52) was amended to provide a manufacturing equipment tax credit. If signed into law, taxpayers would be authorized to take an 

Continue Reading Will California Provide a De Facto Local Tax Exemption for the Sale or Use of Manufacturing Equipment?

In California, spring flowers may bring tax dollars as state Senate Democrats propose increasing the corporate tax rate along with other changes and the California Supreme Court agreed with the

Continue Reading More Taxes in California’s 2023-2024 Budget Plan; CA Supreme Court Declines to Review Sales Tax Case

On April 4, the Internal Revenue Service issued Notice 2023-29 (the Notice), which describes certain rules the IRS intends to include in proposed regulations for qualifying for the energy community

Continue Reading IRS Issues Guidance for Developers, Investors Seeking to Qualify for Energy Community Bonus Credits Under Inflation Reduction Act

On April 10, 2023, the U.S. Treasury Department issued proposed regulations identifying certain micro-captive transactions as listed transactions or transactions of interest for purposes of the disclosure rules for taxpayers

Continue Reading IRS Proposed Regulations Identify Micro-Captive Transactions as Listed Transactions – Responding to CIC Services Decision

The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of

Continue Reading IRS and Treasury Department Finalize Qualified Foreign Pension Funds Regulations

In CIC Services, LLC v. IRS,1 the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act
Continue Reading Court Invalidates IRS Notice 2016-66 on Micro-Captive Transactions, the Second Time an IRS Notice Was Vacated This Month

On 16 February 2022, the Netherlands and Colombia signed a tax treaty for the elimination of double taxation and the prevention of tax evasion and avoidance. The Treaty prevents double

Continue Reading The Netherlands and Colombia Have Signed a Tax Treaty