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Federal Court of Appeal discourages Tax Court from sending out draft judgments to parties
17 Jan 2025 20:08 GMT
… on the practice the Tax Court followed here,” Justice David … decision, the Tax Court prepared the draft ruling by now retired … allow further submissions, the Tax Court committed a reversible error.
… Justice Stratas. “The Tax Court did not commit any reversible …
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Tax court affirms forfeiture of $491,600 undeclared by traveler
17 Jan 2025 08:21 GMT
… (CTA) has affirmed its earlier ruling denying an offer of settlement … Associate Justice Henry Angeles, the tax court denied for lack of merit … under Bangko Sentral ng Pilipinas rules. (PNA)
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IRS Qualified Appraiser Rules
22 Jan 2025 19:00 GMT
Qualified appraisal requirements were enacted to address the abuse of overvaluations of properties contributed to charities. Congress began addressing these issues in the early 1980s. Over the years, the requirements have evolved, culminating in the …
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Tax Court Reaffirms Soroban Holding that “Active” Limited Partners are Subject to Self-Employment Tax
10 Jan 2025 17:50 GMT
… 23, 2024, the Tax Court ruled in Denham Capital Management … The Tax Court found that, consistent with its earlier ruling in … limited partner exception. The Tax Court applied the functional analysis … the Denham and Soroban rulings have further entrenched the …
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The Tax Court Recently Decides Two Research Credit Cases – One Favorable on Funding (Smith) and One Unfavorable on the Four-Part Test (Phoenix Design Group)
09 Jan 2025 21:16 GMT
… designs failed. The court ruled, however, that the contracts … research.
The court also ruled that local law provisions … rationale is dubious. See “Tax Court Denies Research Credits for … com/article/tax-court-denies-research-credits-research-activities …
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New Jersey Tax Court Rules That Individuals Are Not Subject to Tax on “Deemed Dividends” under IRC Section 965
07 Jan 2025 22:59 GMT
The New Jersey Tax Court has held that individual taxpayers were not required to include in their New Jersey gross income the undistributed earnings of controlled foreign corporations (“CFCs”) for purposes of the Gross Income Tax, even though those amounts …
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Tax Court Reaffirmed Soroban’s Holding that Active Limited Partners of State Law Limited Partnerships May Be Subject to Self-Employment Tax
03 Jan 2025 19:20 GMT
… . 2024-114), the Tax Court reaffirmed its earlier ruling in Soroban Capital Partners … . Sirius Solutions is appealing the Tax Court’s similar holding to the … Point72 is still in the Tax Court. For a summary of Soroban …
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RTX Reports 2024 Results and Announces 2025 Outlook
28 Jan 2025 13:24 GMT
… of a recent favorable international tax court ruling related to certain tax … As a result of this ruling, and the expected reimbursement of … response to favorable U.S. Tax Court rulings issued to unrelated taxpayers, … tax item in the rulings is subject to the …
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IRS Aims To Change Rules Governing Tax Professionals
14 Jan 2025 12:19 GMT
… example, to appear in Tax Court on behalf of a client … District Court’s findings, ruling that "[t]he … proposed regulations would eliminate rules regarding registered tax return … education. Under the current rules, continuing education providers that …
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U.S. Tax Court: Proving A Net Operating Loss Deduction Carryover
27 Dec 2024 20:40 GMT
… three recent U.S. Tax Court decisions—all of which sustained … the NOL rules to permit only carryovers.
Recent Tax Court Decisions
In … 2024, the U.S. Tax Court issued three decisions concerning NOL … decisions, the U.S. Tax Court reminded the taxpayers that copies …