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natlawreview.com /2 weeks ago

Pilot Models at Scale: What George v. Commissioner Teaches About the Research Credit

The US Tax Court’s recent decision in George v. Commissioner, T.C. Memo. 2026-10, addressed the application of the Section 41 research credit to supply qualified research expenses...

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wisbar.org /1 month ago

Channels of Tax Law (Mis)Information

With tax-return-filing deadlines upon us, many people will turn to paid professionals for assistance in preparing tax returns or use filing software. Some will visit the IRS’s webs...

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jdsupra.com /3 weeks ago

Recent Internal Revenue Service Private Letter Rulings Clarify Application of Sections 865(h) and 904(h)(10) Under Treat...

Where a treaty permits a foreign jurisdiction to tax income that U.S. law treats as U.S. source, a U.S. taxpayer may be limited in their ability to claim a foreign tax credit unles...

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natlawreview.com /3 weeks ago

IRS Roundup: April 20 – May 1, 2026

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 20, 2026 – May 1, 2026. April 23, 2026: The IRS has reportedly begun...

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natlawreview.com /1 month ago

IRS Roundup: March 23 – March 31, 2026

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 23, 2026 – March 31, 2026. March 23, 2026: A US Treasury Inspector G...

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natlawreview.com /1 month ago

IRS Roundup April 1 – April 9, 2026

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 1, 2026 – April 9, 2026. April 3, 2026: The White House proposed sig...

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natlawreview.com /2 weeks ago

IRS roundup: May 1 – May 11, 2026

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 1, 2026 – May 11, 2026. May 1, 2026: The IRS Office of Chief Counsel i...

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jdsupra.com /1 month ago

Offshore and IRS Tax Lawyer to Protect Your Investments and Interests

Navigating the complexities of the federal oversight, investigations, reporting requirements and challenges of the IRS requires the specialized guidance of an IRS tax lawyer who un...

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taxfoundation.org /1 month ago

Ideas, Not Mandates: Lessons Learned from a Decade of International Tax Reform

The past decade's record suggests that countries have reliable legislative methods to improve their tax systems through ordinary tax reforms.

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jdsupra.com /2 weeks ago

Proactive vs. Reactive: How to Approach R&D Tax Credits

Most companies treat R&D Tax Credits the same way: something that happens to them at the end of the year, once the numbers are in and the accountant has done their work....By:...

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natlawreview.com /2 weeks ago

In Liberty Global, the Tenth Circuit Leaves Taxpayers with an Opinion with Unresolved Questions

On April 21, 2026, in Liberty Global, Inc. v. United States, the Tenth Circuit held that the economic substance doctrine was “relevant” and applied to deny Liberty Global, Inc. a $...

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jdsupra.com /1 month ago

The One Big Beautiful Bill Changed R&D Tax Rules. Here’s What it Means for Your Business.

The R&D Tax Credit changes made in summer 2025 allow taxpayers meeting certain criteria to make a retroactive election to deduct, versus amortize research and experimentation (...

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taxfoundation.org /1 month ago

Certainty Counts: Tax Policy in a Competitive Global Economy

Following the achievements for tax certainty in the One Big Beautiful Bill Act (OBBBA), the Tax Foundation, University of North Carolina Tax Center, and Massachusetts Institute of...

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tax.thomsonreuters.com /1 month ago

Navigating tax challenges for 2026 and beyond: Upcoming compliance hurdles for accounting firms

In a profession built on routine and expertise, regulatory changes can present a major headache for tax professionals. From … The post Navigating tax challenges for 2026 and beyo...

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jdsupra.com /2 weeks ago

New Criteria for Tax Audits and Refunds: Greater Tax Certainty for Your Business

New Criteria for Tax Audits and Refunds: Greater Tax Certainty for Your Business...By: Foley & Lardner LLP

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accountingtoday.com /2 weeks ago

IRS creates significant issue ruling program

The Internal Revenue Service established a program to allow corporate taxpayers to request rulings on certain issues.

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tax.thomsonreuters.com /2 weeks ago

Making the business case for automated direct tax software

Technology investment decisions in finance require more than promises — they demand quantifiable proof. When evaluating automated direct tax … The post Making the business case f...

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tax.thomsonreuters.com /1 month ago

5 best practices for filing sales tax reports: An end-to-end guide to indirect tax compliance

Indirect tax professionals carry one of the most consequential responsibilities in any organization. As the pace of regulatory change … The post 5 best practices for filing sales...

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thetaxtalk.com /1 month ago

DTAA Compliance Gets Stricter: Form 10F Now Mandatory for All Treaty Claims

DTAA Compliance Gets Stricter: Form 10F Now Mandatory for All Treaty Claims A significant procedural shift has been introduced under the Income-tax Act, 2025 and Income-tax Rules...

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natlawreview.com /3 weeks ago

Burlington in the Court of Appeal: New Guidance on Purpose Tests and Access to Treaty Benefits

The Court of Appeal has confirmed in Burlington Loan Management DAC v HMRC that “obtaining the benefit of” a tax treaty is not the same as “taking advantage of” it. The treaty anti...

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natlawreview.com /1 week ago

Tax Planning for Carve-Out and Take-Private Transactions: Use of Selective Section 338 and/or 336 Elections

In carve-out transactions, especially in take-private transactions backed by private equity (PE), tax friction costs can often make or break a deal. By the same token, creative tax...

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thetaxtalk.com /1 month ago

Penalty on Surrendered Income During Survey: Is It Legally Sustainable?

Penalty on Surrendered Income During Survey: Is It Legally Sustainable? A very common situation in tax practice is where unaccounted income is detected during survey proceedings,...

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tax.thomsonreuters.com /1 week ago

State Tax information reporting: What changed in 2025 & what to expect for 2026

The 2025 and 2026 tax filing seasons are on track to have the most state tax information reporting changes … The post State Tax information reporting: What changed in 2025 &...

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accountingtoday.com /4 days ago

In the blogs: Global tax gods

Dangerous procedural traps; justification for change; unexpected tax exposure; and other highlights from our favorite tax bloggers.

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