In accordance with ORS § 314.402, the Oregon Department of Revenue (“DOR”) shall impose a penalty on a taxpayer when it determines the taxpayer “substantially” understated taxable income for any taxable year.
In April 24’s Federal Register, the IRS released proposed regulations (REG-108214-15) to restrict when a foreign insurance company’s income can be excluded as passive income by giving a more strict definition for the “active conduct of an insurance business” exemption under IRC section 1297(b)(2)(B).
The Tax Court recently ruled that a taxpayer was liable for self employment tax based on its status as a partner, even though the partnership had elected out of the partnership tax rules.
There has been considerable coverage in the last week about so-called “like-kind” exchanges of art, and federal tax.
The South Carolina Department of Revenue requested public comment on a draft Revenue Ruling and a draft Revenue Procedure that detail how it will prospectively apply alternative apportionment to multistate taxpayers.
As reported here by the WSJ, increasingly the über wealthy are setting up their own privately-held family trust companies or “FTCs” to handle their trust assets.
Months of anticipation culminated in a successful result for the Liquidators of Bilta (UK) Limited (in liquidation) on 22 April 2015 in a pivotal fraud case, whereby the Supreme Court unanimously dismissed an appeal involving the ‘illegality defence’, in the case of Jetivia SA and another v Bilta (UK) Ltd (in liquidation) and others  UKSC 23.
Appeal of Tax Court Decision Focuses On Foreign Tax Credit, Tests Scope of U.S.-France Totalization Agreement
Briefing is underway in an appeal by two taxpayers—a married couple with dual citizenship in the United States and France—of a U.S. Tax Court decision denying them foreign tax credits for money they contributed to social security payments to France.