IRS Says Not So Fast to States' Attempts to Convert High State and Local Tax Obligations to Charitable Deductions to Escape TCJA Limitations
In Notice 2018-54, the IRS has notified taxpayers that proposed regulations are forthcoming which will deny state attempts to convert a taxpayer’s state and local tax obligations to a charitable deduction in order to avoid the limitations on the deductibility of state and local taxes under the Tax…
Impact to Charitable Organizations under the Tax Cuts and Jobs Act
While many businesses and individuals will see a lower tax bill as a result of the 2017 Tax Cuts and Jobs Act, charitable organizations may ultimately be the biggest losers from the sweeping tax reform. The Tax Act includes several changes that eliminate the tax savings incentives for charitable…
Is the Supreme Court Set to Extinguish Bellas Hess' Bright Line Rule Barring Imposition of Sales Tax on Out-of-State Internet Sellers Later This Year?
February 8, 2018
by Anton L. Janik, Jr.
Twenty-six years ago in Quill Corp. v. North Dakota the U.S. Supreme Court held that the Bellas Hess bright line rule that out-of-state sellers cannot be held liable for collecting and remitting sales tax to any state unless the seller had physical presence in that state, was a precedent that still…
The New Deduction for Pass-Through Income (or How Congress Failed at Tax Simplification)
One of the more significant changes in the recently enacted Tax Cuts and Jobs Act is new Internal Revenue Code Section 199A, Qualified Business Income. Although touted as providing tax simplification, the Tax Cuts and Jobs Act created a pretty complex new tax concept – the pass-through deduction. …
DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters
December 8, 2017
by Anton L. Janik, Jr.
At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue offshore tax prosecution defendants should be sentenced. Instead of…