By H. Jacob Lager of Zuber & Taillieu LLP
The Tax Court has held that the step transaction doctrine did not apply to a series of bargain sales from a family-owned S Corp. to a charitable organization. As a result, the shareholders were entitled to charitable contribution deductions related to the sales. In William R. Klauer v. Commissioner of… More...
In a Private letter Ruling, the Internal Revenue Service (“IRS,” or “Service”) has determined that the amount received from a wrongful death action resolved by legislative settlement is not includible in the gross income under section 104(a)(2), except for any amounts attributable to medical expenses that were in fact deducted on a previous year's federal income tax return. More...
In this Petition for Advisory Opinion, the New York State Department of Taxation and Finance (‘Department”) resolved whether marriage to a same-sex partner will be recognized for New York State personal income tax purposes as a result of Governor David Paterson’s 2008 directive to all State Agencies regarding same-sex marriage recognition. More...
The New York State Department of Taxation and Finance (“Department”) has issued an advisory opinion, stating that a company’s (“Petitioner”) litigation support services delivered online or in tangible format such as DVDs and CDs are not subject to sales and use tax. More...
The United States Tax Court has decided to make electronic filing (“eFiling”) mandatory for most parties represented by counsel (practitioners) in cases in which the petition is filed on or after July 1, 2010. More...
The U.S. Internal Revenue Service (“IRS,” or “Service”) has released a ruling relating to the proper allocation of interest expense of a foreign life insurance company doing business in the U.S. through a branch. More...
Revenue Procedure 2009-47 provides rules for employees who are reimbursed for lodging, meals, and incidental expenses, or meals and incidental expenses only, while traveling away from home, to substantiate the expenses by per diem allowance in lieu of actual expenses. More...
PricewaterhouseCoopers (“PWC”) has released its comments on Internal Revenue Service (“IRS”) Private Letter Ruling (“PLR”) 201002024 relating to the determination of foreign base company sales income (“FBCSI”). More...
The Internal Revenue Service (“IRS,” or “Service”) has issued guidance on the tax treatment of health care benefits provided with respect to children under age 27 under the newly enacted health care law. More...
The Mumbai Income Tax Appellate Tribunal (“MITAT”) has ruled that a company that is based in the United Arab Emirates (“UAE”) and that is also not liable to pay tax in that country can avail of tax exemption benefits provided by the India-UAE Tax Treaty (“Treaty”). More...
California Governor Arnold Schwarzenegger has signed into law SB 401, a legislation that gives tax relief to struggling California homeowners who have sold their homes as short sales or modified their mortgage loans. More...
