Today's modern advertising is causing an upheaval in the way businesses are exposed to potential state tax pitfalls. Influencers are everywhere, impacting consumers' decisions on…
Ownership Without Intermediaries
Comparing Cryptocurrency to Bearer Instruments
Proving one's ownership of cryptocurrency is relatively simple: Possession of a private key, regardless of how it was obtained, entitles its possessor to full control…
The State of US Taxation and its Fiscal Trajectory
Planning Opportunities Under the New Tax Law
In Brief The recently enacted H.R. 1, the so-called One Big Beautiful Bill Act (OBBBA), extends many of the provisions of the Tax Cuts and…
Strategies for Tariff Resilience
How Corporations Can Mitigate Trade Barriers
Tariffs have become a hot topic on any business's agenda. The United States is by far the biggest importer in the world. According to the…
Strategies for Tariff Resilience
How Corporations Can Mitigate Trade Barriers
Tariffs have become a hot topic on any business's agenda. The United States is by far the biggest importer in the world. According to the…
Today's modern advertising is causing an upheaval in the way businesses are exposed to potential state tax pitfalls. Influencers are everywhere, impacting consumers' decisions on…
Ownership Without Intermediaries
Comparing Cryptocurrency to Bearer Instruments
Proving one's ownership of cryptocurrency is relatively simple: Possession of a private key, regardless of how it was obtained, entitles its possessor to full control…
The State of US Taxation and its Fiscal Trajectory
Planning Opportunities Under the New Tax Law
In Brief The recently enacted H.R. 1, the so-called One Big Beautiful Bill Act (OBBBA), extends many of the provisions of the Tax Cuts and…
The U.S. Supreme Court's landmark decision in South Dakota v. Wayfair, Inc. (138 S. Ct. 2080, 2018) overturned years of precedent that had precluded states…
The U.S. Supreme Court's landmark decision in South Dakota v. Wayfair, Inc. (138 S. Ct. 2080, 2018) overturned years of precedent that had precluded states…
Considerations for Tax Return Preparers Outsourcing Overseas
Obtaining Taxpayer Consent Under IRC Section 7216 and Related Authorities
As early as 2006, the IRS has recognized that “foreign outsourcing is not prohibited by … final regulations, which permit disclosure of tax return information…
Amid the flurry of proposed rulemakings that were published in the month prior to President Trump's inauguration, the Treasury Department published the long-awaited proposed amendments…
Amid the flurry of proposed rulemakings that were published in the month prior to President Trump's inauguration, the Treasury Department published the long-awaited proposed amendments…
State Tax Updates in Key Jurisdictions
Changes in Massachusetts, New Jersey
CPAs need to be aware of current tax developments in key states to properly advise taxpayers doing business in multiple jurisdictions. It is crucial to…
Florida’s Apportionment/Sourcing of Sales Dilemma
A Brief Overview
Over the years, Florida's sales factor sourcing methodology for sales of other than tangible personal property has been the subject of various interpretations by both…
The number of incidents of fraud perpetrated against individuals and the resulting loss amounts have both drastically increased in recent years. In 2018, the Federal…
In 2021, the IRS announced an enforcement campaign targeting high-income U.S. citizens who were purportedly claiming tax exemptions through Puerto Rico's Act 22 and Act…
Florida’s Apportionment/Sourcing of Sales Dilemma
A Brief Overview
Over the years, Florida's sales factor sourcing methodology for sales of other than tangible personal property has been the subject of various interpretations by both…
In 2021, the IRS announced an enforcement campaign targeting high-income U.S. citizens who were purportedly claiming tax exemptions through Puerto Rico's Act 22 and Act…
The number of incidents of fraud perpetrated against individuals and the resulting loss amounts have both drastically increased in recent years. In 2018, the Federal…
Global Mobility and US Taxes
Identifying Risks for Foreign Individuals and Entities
Today's global workers and their employers are at risk of triggering US tax and compliance obligations. The stakes are high for CPAs serving global clients,…
CPAs need to be aware of current tax developments impacting all state and local tax jurisdictions in order to properly advise businesses operating in multiple…
A number of government officials have recently accused Real Estate Investment Trusts (REIT) in the healthcare and hospitality sector of violating tax rules and have…
SALT Round-Up—Current Developments in Key Jurisdictions
Looking at New York, Tennessee, Virginia
CPAs need to be aware of current tax developments in key states to properly advise employers and clients doing business in multiple jurisdictions. As state…
The New Administrative Law
Overview of the Potential Impact of Loper Bright and Corner Post on Tax Cases
In a landmark term for administrative law, the Supreme Court issued two opinions earlier this summer that will have significant implications for future litigation regarding…
The New State of Administrative Law
Overview of the Potential Impact of Loper Bright and Corner Post on Tax Cases
In a landmark term for administrative law, the Supreme Court issued two opinions earlier this summer that will have significant implications for future litigation regarding…
ICYMI | Supreme Court Defers Fundamental Constitutional Question in Upholding Tax on Foreign Business Income
A First Look at the Decision in Moore
In Charles G. Moore v. United States (No. 22-800), petitioners challenged Congress’s authority to tax unrealized gains under the Sixteenth Amendment. The tax at issue…
In Brief Social Security remains a critical component of most Americans' financial and retirement plans. Despite its longevity and familiarity, many individuals are unaware of…
Major changes to estate and gift taxes are periodically a topic of discussion in Congress and the popular press. The Tax Cuts and Job Act…
Controlled Foreign Corporation Stock Loss in Disaster Area Disallowed
IRS Chief Counsel Limits Deductibility
In Chief Counsel Advice Memorandum 202325007 (https://www.irs.gov/pub/irs-wd/202325007.pdf, Mar. 22, 2023), legal staff within the IRS determined that a worthless stock loss did not occur within…