Latest COST Conscious

ISSUE 24-08; April 19, 2024

State Corporate Income Tax Filing Methods (Part 1) – In recent years, many states have either changed or considered changing their default corporate tax filing. New Jersey adopted water’s-edge combined reporting in 2019 only to come back in 2023 with a proposal to allow the Director of Tax to “decombine” taxpayers. Maine, New Hampshire, and Vermont have studied the implementation of mandatory worl

Latest Legislative Alert

ISSUE 24-17; April 23, 2024

COST Opposes Base Erosion Study and Tax Disclosure in Minnesota; COST Opposes New California Digital Advertising Services Tax Legislation

Latest Practitioner Connection

ISSUE 24-09; April 26, 2024

The Advantages of Litigating Tax Disputes – Most often, state and local tax litigation follows the escalation of an administrative controversy from the denial of a protest, refund claim, or other tax agency determination. While there are times when litigation is the only remaining option, the decision whether or not to proceed with litigating a tax case is often a strategic one. Of course, prevail

BLOOMBERG TAX

Medtronic Wants Cardiac Monitors to Avoid California Sales Tax

April 26, 2024

Medtronic USA Inc. told a California appeals court Friday that implanted devices used to detect irregular heartbeats are exempt from sales tax because they qualify as medicine under state law.

Retaliation Suit Over Suspected Tax Fraud Reporting May Proceed

April 26, 2024

An Ohio medical services provider must face the lawsuit of former employee who says he was wrongfully terminated after internally reporting the company's suspected tax fraud, a federal court said.

Kansas House Votes to Override Gov. Kelly’s Latest Tax Cut Veto

April 26, 2024

Kansas’s ongoing tax policy drama took an unsurprising turn Friday when a bipartisan majority of House members voted overwhelmingly to override Gov. Laura Kelly’s veto of the Legislature’s most recent tax reduction plan.

IRS PLR: Extension of Time Granted to Elect to Certify as a Qualified Opportunity Fund (IRC §1400Z)

April 26, 2024

The IRS has published a private letter ruling on section 1400Z and Treasury Regulation Section 301.9100 regarding extensions of time to make an election to be certified as a qualified opportunity fund for federal tax purposes. [PLR 202417001]

IRS PLR: Extension of Time Granted to Elect to Certify as a Qualified Opportunity Fund (IRC §1400Z)

April 26, 2024

The IRS has published a private letter ruling on section 1400Z and Treasury Regulation Section 301.9100 regarding extensions of time to make an election to be certified as a qualified opportunity fund for federal tax purposes. [PLR 202417011]

State of Tax: Disney, IBM Fallout; California Digital Ad Tax (1)

April 26, 2024

The week in state tax news: Companies with business in New York and California have their eyes on legal stories with millions in tax-dollar implications—one, the loss that Disney and IBM just experienced in New York, the other a slew of pleadings to a California tax agency about its Microsoft decision. Meanwhile, a tax on digital advertising revenue advanced in California's Assembly, and Tennessee lawmakers agreed to give companies $1.55 billion in franchise tax refunds.

IRS PLR: Proposed Transactions Excludable From Gross Income (IRC §101)

April 26, 2024

The IRS has published a private letter ruling on Section 101, regarding certain transactions being excluded from gross income. [PLR 202417006]

IRS PLR: Implementation of Final Rate Order Violate Consistency Rules (IRC §168)

April 26, 2024

The IRS has published a private letter ruling on Section 168 regarding the violations of the consistency rules through the implementation of a final rate order. [PLR 202417002]

Ex-Moody’s Counsel Admits to Not Filing Taxes on $54 Million (1)

April 26, 2024

The former general counsel for Moody's Corp. pleaded guilty to willfully failing to file federal income tax returns over four years, during which he earned more than $54 million, federal prosecutors said Friday.

IRS PLR: Professional Corporation to Become Member of Parent Group Filing Consolidated Return (IRC §1504)

April 26, 2024

The IRS has published a private letter ruling on Section 1504, holding that the Taxpayer, a Professional Corporation (PC), will become a member of the Parent Group required to file a consolidated federal income tax return with the Parent Group upon its execution of the Stock Transfer Restriction and Support Services Agreements. [PLR 202417008]