Latest 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.

Latest 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

Latest Practitioner Connection

ISSUE 24-23; November 8, 2024

GeTtin’ SALTy Episode 40: A Conversation about State Tax Ballot Initiative Results – In this episode of the GeTin' SALTy podcast, host Nikki Dobay is once again joined by Jared Walczak, Vice President of Special Projects at the Tax Foundation, to discuss the state tax ballot initiatives results from the Nov. 5, 2024 election. Nikki Dobay, Greenberg Traurig LLP, November 8, 2024.

BLOOMBERG TAX

Apollo Faces CEO Question and Golden Moment If Rowan Heads to DC

November 20, 2024

Apollo Global Management Inc. Chief Executive Officer Marc Rowan’s potential next act as US Treasury secretary would thrust the firm he co-founded into an entirely new era of leadership. It may also help unlock trillions of dollars for its hottest business line.

Switzerland to Amend Global Minimum Tax Law to Allow for New Tax

November 20, 2024

Switzerland said Wednesday it was amending its legislation implementing part of the global minimum tax, to allow for a tax it imposed in September.

New York’s Lawler Says SALT Cap Must Go to Pass GOP Tax Bill

November 20, 2024

A New York Republican congressman says that lifting the cap on state and local taxes will be crucial to getting President-elect Donald Trump’s tax overhaul through the House, given the party’s narrow majority in the chamber.      

Mali Frees Resolute Executives After $160 Million Deal: AFP (2)

November 20, 2024

Mali has released three Resolute Mining Ltd. executives after the African nation detained them in a tax dispute, Agence France-Presse reported, citing a judicial source and a local gold mine official.

UK Top Court Denies Data Centers’ Capital Allowance Claims

November 20, 2024

The UK’s top court denied capital allowance claims by two data center companies after determining £96 million ($121 million) in construction contracts weren't awarded by a statutory deadline.

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]