July 10, 2026, was widely publicized as the deadline for filing refund claims under Section 7508A. That date was calculated by adding the ordinary three-year limitations period to July 10, 2023, the end of the COVID disaster-relief period that Kwong…
The American economy has undergone a structural shift, and state taxing authorities are trying to catch up. Some of the largest and most profitable companies in the world generate hundreds of billions of dollars annually not by selling a product…
There may be a meaningful opportunity for conservation easement investors to recover a portion of the interest paid to the IRS after a partnership adjustment. Recent court decisions interpreting the COVID-era disaster-relief rules under Section 7508A(d) have created a path…
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…
Footnotes: [1] City of Atlanta, FY 2026 Operating Budget, at 27 (June 2025), available at https://www.atlantaga.gov/home/showpublisheddocument/65298. [2] O.C.G.A. § 48-13-6. [3] Atl. Code § 30-51 et seq. [4] See Atl. Code §§ 30-66(b), 30-71(b). [5] See Atl. Code §§ 30-69….
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…
IRS Launches Audit Campaign on Business Aircraft Use The IRS announced on February 21 that it will start an audit campaign investigating potential personal use of business aircraft. The campaign will begin with a few dozen audits, but the IRS has indicated…
Congratulations! You’ve reached a basis for settlement with the Appeals Officer. In previous articles, we’ve provided pointers on the Protest, Preparation, Presentation, and Persistence. The end is in sight, but you must finish it well. In this article, we will…
You are in the middle of your initial conference with the Appeals Officer. So far, you’ve been able to keep to your well-prepared script. Your protest went through several drafts until you decided that not a word needed to change. Through your preparation for…
