Florida law requires multistate businesses to apportion income using a three-factor formula based on property, payroll, and double-weighted sales.[1] Last month, Apple Inc. and Verizon Communications, Inc. each filed lawsuits against the Florida Department of Revenue (the “Department”) in the…
Last week, the U.S. House of Representatives narrowly passed a budget resolution calling for $4.5 trillion in tax cuts and $2 trillion in spending cuts. The House plan would significantly reduce federal funding for Medicaid, food assistance, and other safety-net…
Tax Court Clarifies SECA Tax Applicability to Active Limited Partners Last month, the Tax Court issued another decision addressing the meaning of limited partner for private equity and hedge fund managers, once again subjecting the managers to Self-Employment Contributions Act…
Just over a year ago, the IRS––armed with Inflation Reduction Act (IRA) funding and resources––announced how the increased funding would be put to use. Enforcement initiatives were aimed at corporate taxpayers and included “a large foreign-owned corporations transfer pricing initiative.” As part…
For those of us justifiably dissatisfied with this season of House of the Dragon, recent ERC action may lend some much-needed excitement—some might say gore? Last month, the IRS issued nearly 30,000 denial letters to taxpayers for ERC claims it…
With a flurry of IRS announcements regarding wealthy individuals and large partnerships, recent guidance on related-party basis transactions may have been easily overlooked. For many, this oversight may be a non-issue. But some unsuspecting taxpayers may find themselves ill-prepared to…
On June 18, 2024, the IRS modified the required information taxpayers must provide to the Service when submitting an I.R.C. § 41 research credit refund claim. The IRS had previously released a memorandum in October 2021 instituting five required pieces of information…
On June 28, 2024, the Supreme Court issued its long-awaited opinion in Loper Bright Enterprises et al. v. Raimondo, Secretary of Commerce, et al., overturning decades of judicial deference to agencies’ regulations. The Court overturned its forty-year-old precedent, Chevron U.S.A Inc. v….
The IRS has finally come up for air to offer insight into its months-long “review period” of pending Employee Retention Credit (“ERC”) claims. On June 20, 2024, the agency announced that it will begin issuing payments on roughly 10 to…
The Supreme Court released its eagerly awaited opinion in Moore v. United States yesterday. The majority opinion is carefully uncontroversial. The Court held that Congress may tax an entity’s undistributed income to either the entity or its shareholders or partners. For partners…
