United States: Tax Authorities

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Podcast
GeTtin’ SALTy Episode 76 | California Court Of Appeal Rejects FTB’s Unitary Business Theory For Individuals In Garcia-Rojas: A Win For Non-Resident Sole Proprietors (Podcast)
A Texas-based radiologist who performed all work from his home state faced California income tax assessments on earnings from a California company contract. The California Court of Appeal rejected the Franchise Tax Board's attempt to apply the unitary business principle to a sole proprietor, creating new grounds for non-resident individuals to challenge similar assessments.
United States Tax
GT
Greenberg Traurig, LLP
Article
Internal Revenue Service Publishes Final Rule For “No Tax On Tips” Deduction
The IRS has finalized its list of occupations eligible for the income tax deduction on qualified tips under the "One Big Beautiful Bill Act," making only minor modifications from its preliminary guidance. Employers must now prepare to report employee occupation codes and cash tip amounts on 2026 Form W-2s, while navigating new rules that distinguish between qualifying and non-qualifying tips based on job duties and payment circumstances.
United States Tax
LM
Littler Mendelson
Article
Bitcoin Black Sheep, Stablecoin Favorite Child Under Revised Crypto Bill
A revised bipartisan crypto tax bill introduces significant changes to how cryptocurrency transactions are taxed, including new rules for staking rewards deferral and stablecoin basis calculations. The legislation proposes different treatment for proof-of-stake versus proof-of-work validation methods, while establishing a 99-cent basis threshold for regulated payment stablecoins pegged to the U.S. dollar.
United States Technology
CW
Cadwalader, Wickersham & Taft LLP
Article
Streamlined Extension Process Now Available For Employers Facing ERC Claim Disallowance Deadlines
The IRS has introduced a streamlined process allowing employers with disallowed COVID-era Employee Retention Credit claims to request additional time for administrative appeals before their statutory deadline to file suit expires. Employers with six months or less remaining may now submit Form 907 through a new online tool to preserve their refund rights while claims remain under review.
United States Tax
LL
Liskow & Lewis
Article
Zero, Zip, Zilch, Nada: No Basis In Partner Contributed Note
The Tax Court's recent decision in Continental Grand Limited Partnership v. Commissioner addresses the complex interplay between retroactive entity classification elections and partnership basis calculations. When a German subsidiary retroactively elected to be disregarded as a separate entity before contributing a $610 million promissory note to a U.S. partnership, the court reordered the transaction with significant tax implications. The ruling extends established zero-basis principles to situations...
United States Tax
CW
Cadwalader, Wickersham & Taft LLP
Video
Webinar – How Does EBITDA Help Establish Value Of Business In WA (Video)
Attorney David C. Tingstad explores the critical role of EBITDA (Earnings Before Interest, Taxes, Depreciation, and Amortization) in determining business valuation within Washington State. This webinar examines how this financial metric serves as a foundational tool for establishing fair market value in business transactions and legal proceedings. Understanding EBITDA's application can significantly impact negotiations, sales, and dispute resolutions involving business worth.
United States Tax
BB
Beresford Booth
Article
GC Bootcamp For Family-held Business: Introduction To Estate Planning, Taxes & Family Offices
Explore how legal professionals navigate complex regulatory frameworks and client relationships in today's evolving business landscape. Discover the strategic approaches and specialized expertise that drive successful outcomes in corporate legal matters. Learn about the critical considerations that shape modern legal practice and professional development.
United States Commercial
FL
Foley & Lardner
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