Taxes

Over half the states that levy a corporate income tax employ the single-factor receipts formula to apportion corporate income for sales other than tangible personal property. Market-based sourcing is the predominant approach to assigning service receipts to the appropriate state, but three states — Delaware, Mississippi, and Texas — use the service performance method, and

Stephanie Hunter McMahon of the University of Cincinnati College of Law discusses why labor performed by incarcerated workers should be subject to tax. This transcript has been edited for length and clarity. David D. Stewart: Welcome to the podcast. I’m David Stewart, editor in chief of Tax Notes Today International. This week: prisoners’ dilemma. On

Businesses making investments in research are baffled that the current federal tax code severely limits tax incentives for innovation. The background is this: The Tax Cuts and Jobs Act (“TCJA”) passed in 2017 required the capitalization of research and experimental (“R&E”) expenditures over a 5-year period (a 15-year period for foreign research) starting for taxable

IRS Forms 1099 arrived around the end of January 2023 for 2022 payments. The IRS likes these forms, which allow computer matching of your Social Security Number against your tax return. Businesses issue the forms to anyone who receives $600 or more for services during the year. There are many types of 1099. For example,

The full Tax Court in one of its regular decisions (Green Valley Investors LLC) has dealt a blow against the IRS in its struggle with abusive syndicated conservation easements. A key IRS move in the fight was Notice 2017-10 which made certain syndicated conservation easement transactions “listed transactions”. The reporting regime that listed transactions are

Are you bullish about the stock markets in 2023? If so, you may be looking at year-end strategies to prepare for brighter investing horizons. For example, after the stock market declines of 2022, you may now hold securities—whether stocks, ETFs, or mutual funds—that would generate capital losses if sold. Those losses could then be used

As Washington digests the midterm elections, one thing is clear—America’s cities shouldn’t expect new help from a divided and likely deadlocked Congress. With cities facing difficult economic circumstances and tight budgets, federal help in the next two years can only come from the executive branch, and from the impacts of programs President Biden passed in

Trying to keep the lid on federal borrowing with a statutory debt limit is like trying to manage your weight by refusing to buy bigger pants. Neither actually works because both are forms of performative discipline. Each involves an expression of hard-nosed determination, but neither involves any actual hard work. Ultimately, if you want to

Another twist in the never-ending saga that is the United States’ pursuit of a corporate minimum tax. For the past year, Treasury Secretary Janet Yellen expressed optimism that the U.S. would help the OECD’s push for a global minimum tax get across the finish line. That optimism hasn’t waned, even when the Biden administration encountered

Many taxpayers and tax advisers have trouble saying exactly why one should get a tax opinion or how to use it. A tax opinion can be about almost any tax issue. A good tax opinion discusses the facts, legal arguments, and pertinent authorities. One portion of the opinion says, “it is our opinion that….” But