Upcoming National Meeting

2024 Canadian Tax Workshop For U.S. Companies

The COST Canadian Tax Workshop for US Companies covers the key tax issues U.S. companies who are doing business with Canadians or in Canada need to know. The primary focus of the Workshop will be on GST, HST and Income Tax but will also cover QST, Payroll and Property Taxes. Attendees will also participate in an interactive audit session covering Canadian tax issues that they’ve been dealing with.

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Newsletters & Media

Legislative Alert

ISSUE 24-42; November 19, 2024

Louisiana Session Update: COST Opposes Repeal of Vendor’s Compensation; Texas Comptroller Schedules Hearing on Proposed Amendments to Tex. Admin. Code § 3.330

Cost Conscious

ISSUE 24-23; November 15, 2024

Work Location Trends – Many companies are reviewing their current work location practices in an effort to balance an in-person team dynamic with many staff members’ desire to work remotely. Which of the following best describes your company’s current policy? Choose one.

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Bloomberg TAX

IRS PLR: Extension Granted for Taxpayer’s Change in Method of Accounting Related Party Transactions (IRC §267)

November 20, 2024

The IRS has published a private letter ruling on Section 267 and Treasury Regulation Sections 1.267 and 301.9100 granting taxpayer an extension of time to file Form 3115 changing taxpayer's method of accounting for certain related party transactions pursuant to Treasury Regulation Section 1.267(a)-3 under Rev. Proc. 2015-13 and Rev. Proc. 2022-14, with an amended federal income tax return for a certain taxable year. [PLR 202446011]

Multistate Tax Group Rejects Real-Time Sales Tax Audit Scheme

November 20, 2024

The Multistate Tax Commission voted to suspend consideration of a proposal for “real-time” sales tax audits of large retailers, finding no urgency for the initiative and limited resources within the intergovernmental tax agency to pursue it.

IRS PLR: Trust Determined a Qualified Settlement Fund, Transfers of Funds From Trust Excludable (IRC §468B)

November 20, 2024

The IRS has published a private letter ruling on Section 468B, and Treasury Regulation Section 1.468B, determining that a trust satisfied the three requirements of Treasury Regulation Section 1.468B-1(c) and is a qualified settlement fund for federal income tax purposes. The IRS also determined that the trust can exclude from its gross income, under Treasury Regulation Section 1.468B-2(b)(1), transfers of funds from a Court ordered trust established to aid in the administration of settlements between plaintiffs and defendants. [PLR 202446003]

Florida Men Sentenced for Role in $3 Million Tax Fraud Scheme

November 20, 2024

Two Florida men were sentenced for their involvement in the "Note Program," a tax fraud scheme, the Justice Department announced Wednesday.

IRS PLR: Exchange Trust Certificates Qualify as Stripped Coupons, Bonds (IRC §1286)

November 20, 2024

The IRS has published a private letter ruling on Section 1286 and Treasury Regulation Section 301.7701 determining that: 1) certain exchange certificates to be issued by an exchange trust will qualify as interests in stripped coupons or stripped bonds within the meaning of Section 1286, assuming that all exchange certificates issued by the exchange trust will not be held by one person; and 2) the exchange trust’s exchange mechanism, including the ability to exchange fixed rate real estate mortgage investment conduit certificates or grantor trust certificates for floating rate and inverse floating rate exchange certificates, will not cause the exchange trust to fail to be classified as a fixed investment trust under Treasury Regulation Section 301.7701-4(c). [PLR 202446009]

IRS PLR: Trust Determined a Qualified Settlement Fund, Transfers of Funds From Trust Excludable (IRC §468B)

November 20, 2024

The IRS has published a private letter ruling on Section 468B, and Treasury Regulation Section 1.468B, determining that a trust satisfied the three requirements of Treasury Regulation Section 1.468B-1(c) and is a qualified settlement fund for federal income tax purposes. The IRS also determined that the trust can exclude from its gross income, under Treasury Regulation Section 1.468B-2(b)(1), transfers of funds from a Court ordered trust established to aid in the administration of settlements between plaintiffs and defendants. [PLR 202446005]

IRS PLR: Distribution Pending Court Order Qualifies as Contingent Set-Aside (IRC §4942)

November 20, 2024

The IRS has published a private letter ruling on Section 4942 and Treasury Regulation Section 53.4942 determining that a certain amount which would have been distributed by a tax-exempt private foundation before Dec. 31, 2022, but for a court order precluding the distribution, qualifies as a contingent set-aside described in Treas. Reg. Section 53.4942(a)-3(b)(9) for taxable year ended Dec. 31, 2022. [PLR 202446016]

IRS PLR: Trust Determined a Qualified Settlement Fund, Transfers of Funds From Trust Excludable (IRC §468B)

November 20, 2024

The IRS has published a private letter ruling on Section 468B, and Treasury Regulation Section 1.468B, determining that a trust satisfied the three requirements of Treasury Regulation Section 1.468B-1(c) and is a qualified settlement fund for federal income tax purposes. The IRS also determined that the trust can exclude from its gross income, under Treasury Regulation Section 1.468B-2(b)(1), transfers of funds from a Court ordered trust established to aid in the administration of settlements between plaintiffs and defendants. [PLR 202446004]

NY Lawmakers Pledge Scrutiny on Tax Breaks After Critical Report

November 20, 2024

New York lawmakers said they will pursue changes to tax incentive programs in next year's legislative session, in response to an audit that found many of the credits don't provide the state with a positive return on investment in the form of jobs and broader economic development.

Barnes & Thornburg Recruits Maya Grassi as Corporate Partner

November 20, 2024

Maya Grassi joined Barnes & Thornburg as a partner in its corporate department in Washington, the firm announced Wednesday.

Featured Resources

COST - Council on State Taxation

Amicus Briefs

COST - Council on State Taxation

COST Studies, Articles & Reports

2024 State and Local Amnesty Programs

Tracker of most state and local tax amnesty programs enacted and conducted in 2024.

COST - Council on State Taxation

COST Comments & Testimony

Testimony In Opposition to Repeal of Vendor’s Compensation in House Bill 10

COST urges Louisiana’s Senate Revenue and Fiscal Affairs Committee to remove provisions in House Bill 10 that would eliminate vendor’s compensation, which is an essential element of a fair and efficient sales tax system.