A court’s final decision in a partnership-level proceeding may feel like the end of the road. But for the individual partners, the conclusion of a partnership examination often marks the beginning of a new and equally consequential phase: the IRS’s…
The economic substance doctrine originated in federal income tax law but now plays an expanding role in state and local tax controversies. This article outlines the doctrine’s federal foundations and examines how states increasingly deploy it as a tool to…
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…
IRS Launches New Workgroup to Target Pass-Through Entities On September 20, 2023, the IRS created a new workgroup to substantially expand enforcement efforts related to pass-through organizations not subject to corporate income tax, including partnerships and S-corporations. The new unit, established under…
