TAX COURT JUDGMENT BOROUGH TO APPEAL TAX COURT JUDGMENTBOROUGH TO APPEAL TAX COURT JUDGMENTMONSY ALVARADO, Staff Writer
Appeal of Tax Court Decision Focuses on Foreign Tax Credit, Tests Scope of U.S.-France Totalization AgreementMcKnight, Katherine
prior to initiating tax assessment proceedings, must inform the taxpayer of its intentions and reasons for the assessment. This is important, as it aims to balance the rights of the taxpayer to make their case (before the government takes action that affects them directly) with the need for...
Shouldn’t those problems be fixed before giving the IRS more power, more money, and more of our private data? I’ll close by wondering whether either Rampell or Appelbaum have voluntarily paid extra tax to demonstrate their own “patriotism”? Or, if that’s asking for too much flag ...
the liability in a reasonable amount of time, offers in compromise can be an effective way to settle a tax liability for less than its total amount. Offers in compromise also have the effect of suspending collection action and allowing the taxpayer to regroup while it negotiates with the IRS...
Fortunately, they do get a credit for some of the taxes they pay to foreign governments. And there’s also a “Section 911” exclusion that allows them to avoid double taxation on income below a certain level. But the overall effect is a system that – at best – is a compliance nightm...
The Federal Court of Appeal recently released its decision inBozzer v. The Queen, 2011 FCA 186. Since the introduction in 2004 of a 10-year limitation period for interest and penalty relief under subsection 220(3.1) of the Income Tax Act, the CRA has administered the provision as if the ...
Miracle for Israel (NGO) More Work highlights Represented the Stein family before the Supreme Court in a ruling where the court dismissed an appeal by the Israel Land Tax Authority. Represented high-tech company Amdocs before the Supreme Court in a precedential ruling where the court dismissed the...
The 2023–24 year saw changes implemented to NSW’s duty legislation with the effect of significantly expanding the NSW duty base, including: a widening of the net for transactions that will be captured for landholder duty purposes (broadly, duty charged on transactions of interests in entities ...
The Public Notice also announces that the filing of TP returns and CbCR notifications have been migrated from e-TP Plat to the TaxProMax platform. The migration takes effect immediately and will apply to all future TP filings. Taxpayers may also choose to refile their previously filed returns ...