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The purpose of this brief is to correct and respond to two arguments in Petitioner-Appellee Altera's petition for rehearing en banc and briefs of amici supporting the petition for rehearing. First, Treasury's regulation requiring cost sharing of stock-based compensation and the Ninth Circuit...
Persistent link: https://www.econbiz.de/10012863203
This report describes various tax games, roadblocks, and glitches in the tax legislation currently before Congress, titled the Tax Cuts and Jobs Act (TCJA). The complex rules proposed in the House and Senate bills will allow new tax games and planning opportunities for well-advised taxpayers,...
Persistent link: https://www.econbiz.de/10012931759
Persistent link: https://www.econbiz.de/10012944344
The 2017 tax legislation brought sweeping changes to the rules for taxing individuals and business, the deductibility of state and local taxes, and the international tax regime. The complex legislation was drafted and passed through a rushed and secretive process intended to limit public comment...
Persistent link: https://www.econbiz.de/10012900402
For more than seven decades, state and local governments as well as market actors have labored under an export tax regime that is inconsistent, inefficient, and inequitable. The petition for a writ of certiorari in Loudoun County, Virginia, v. Dulles Duty Free, LLC, presents the Supreme Court...
Persistent link: https://www.econbiz.de/10014116849
In this article, the authors critically appraise the government’s proposal not to allocate research and development deductions to subpart F inclusions and global intangible low-taxed income for foreign tax credit limitation purposes. They say the proposal is an unprecedented interpretation of...
Persistent link: https://www.econbiz.de/10013226626