In an opinion issued on June 26, 2013, the U.S. Supreme Court declared unconstitutional Section 3 of the Defense of Marriage Act (“DOMA”), which had prohibited the recognition of same-sex couples as “spouses” under federal law
The IRS and Treasury announced taxpayer-favorable guidance regarding the grandfathering of pre-2014 projects for the purposes of the renewable electricity production tax credit (PTC) or the energy investment tax credit (ITC).
Recently there has been increasing debate regarding if and when assessing jurisdictions, or its agents, can invade the privacy of New York residents. Even New York’s governor has been impacted by this issue.
Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on two categories of income: (i) certain types of passive U.S.-source income (e.g., interest, dividends, royalties and other types of “fixed or determinable annual or periodical income,” collectively known as FDAP), which are subject to a 30-percent gross basis withholding tax; and (ii) income that is effectively connected to a U.S. trade or business (ECI), which is taxed at graduated tax rates applicable to U.S. persons.
The United States Tax Court released an opinion today, Whistleblower 22231-12W v. Commissioner of Internal Revenue, which continues to piece together the bounds of the Tax Court’s jurisdiction.