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

Cost Conscious

ISSUE 24-21; October 18, 2024

Property taxes account for the largest percentage of state and local taxes paid by businesses and is also often the largest percentage paid by individual homeowners. Property tax reductions are currently a significant focus of many state legislatures. For example, North Dakota voters will consider an initiative to practically eliminate the property tax, while voters in other states, such as Nebras

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Bloomberg TAX

UK Minimum Wage to Rise by 6.7% Next Year, Exceeding Inflation

October 29, 2024

The UK minimum wage will rise by an inflation-busting 6.7% next year, an increase that helps Chancellor of the Exchequer Rachel Reeves argue working people are protected at Wednesday’s budget, but may complicate the Bank of England’s inflation fight.

Poland Widens 2024 Budget Gap Due to Lower Tax Inflows and Flood

October 29, 2024

Poland’s government revised up its 2024 budget deficit as lower than expected value-added tax revenues strain the fiscal plan along with additional spending triggered by a devastating flood. 

BTAX OnPoint: OECD’s Pillar 2 Subject to Tax Rule

October 29, 2024

The Subject to Tax Rule allows developing countries that are members of the OECD’s Inclusive Framework to reclaim some source jurisdiction taxing rights ceded under tax treaties with developed nations.

American Tax Breaks Are Funding China’s Dominance in Solar Tech

October 29, 2024

Companies based in or linked to China are building or planning to build at least a dozen plants with 30 gigawatts of module-making capacity, according to a Bloomberg review of public statements, filings, and other documentation. All told, the facilities would be able to supply roughly three-quarters of today’s US panel needs.

Andrew Jackson Recruits Devon Drakes to Private Client Team

October 29, 2024

Solicitor Devon Drakes joined the private client team at Andrew Jackson Solicitors LLP, the firm announced Tuesday.

Metals Depository Owner Convicted of Mail, Wire, Tax Fraud

October 29, 2024

A Delaware precious metals depository owner was convicted on charges of mail, wire, and tax fraud, the Justice Department announced on Monday.

Kenya’s Supreme Court Gives Ruto Some Respite in Tax-Law Ruling

October 29, 2024

Kenya’s Supreme Court ruled that a set of tax measures introduced in the 2023 budget wasn’t entirely unlawful, throwing a lifeline to President William Ruto’s government that’s struggling to make ends meet.

US, Taiwan to Begin Talks on a Deal to Address Double Taxation

October 29, 2024

The US and Taiwan will begin negotiations on addressing double taxation issues, paving the way for a deal that could reduce hurdles for businesses and boost investment in the semiconductor industry.

Case: Prior Administrative Claim Must Have Been Filed with IRS to Invoke Federal Claims Court Jurisdiction (Fed. Cl.) (IRC §7422)

October 29, 2024

Taxpayer could not invoke the court’s jurisdiction for his tax refund claims before filing an administrative claim with the IRS, the U.S. Court of Federal Claims held, dismissing the case. Taxpayer, an individual, filed Forms 1040 for tax years 2018 and 2019. For 2018, Taxpayer reported social security tax withholding of $25, zero withheld federal income tax, and did not request a refund. For 2019, Taxpayer claimed a tax refund of $724 and, after receiving only a portion at first, was eventually paid the remainder plus interest. Taxpayer sent a series of letters to the IRS about a 2018 tax refund. His first letter indicated his intention to amend his 2018 tax return and to request a refund of $88. Although the IRS received an amended return around the same time, the amended return was a duplicate of the original. In March 2024, Taxpayer filed suit against the IRS in the federal claims court, seeking a tax refund of $25 for tax year 2018 and $724 for tax year 2019. Under I.R.C §7422(a), a taxpayer must file a tax refund claim with the IRS before seeking judicial remedies. Noting that §7422(a) is a jurisdictional requirement, the court held that it lacked subject matter jurisdiction over Taxpayer’s 2018 refund claim because: (1) he failed to request a refund in his original or amended return; (2) even if his correspondence constituted an informal refund request, he failed to perfect the claim; and (3) to the extent Taxpayer sought a refund of social security tax, he failed to file Form 843. The court dismissed Taxpayer’s 2019 claim because Taxpayer acknowledged he received a refund for the amount he alleged he was owed. [Duke v. United States, No. 24-581T (Fed. Cl. Oct. 25, 2024)]

US, Taiwan to Start Talks on Pact to Address Double Taxation

October 29, 2024

The US and Taiwan will begin negotiations on a comprehensive agreement to address double taxation issues, according to a statement released by the Treasury Department.

Featured Resources

COST - Council on State Taxation

Amicus Briefs

International Business Machines Corporation and Combined Affiliates v. New York State Tax Appeals Tribunal

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

Comments on Texas Proposed Rule 3.330

On October 11, COST submitted comments to the Texas Comptroller suggesting proposed changes to Rule 3.330 represent an expansion of the sales tax base that is not supported by any statutory change and is in direct opposition to Texas Supreme Court jurisprudence. The comments also request a hearing and recommend that any change in administrative policy should apply only prospectively.