United States: The IRS shoots down advance payments of 367(d) annual inclusions
In Advice Memo 2022-003 (AM) released on 23 September 2022, the IRS takes a stance on advance payments of annual inclusions within section 367(d)…
Source: lexology.com
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United States: Everybody loves (Clark) Raymond, but did the Tax Court get it Right?
In Clark Raymond & Co., PLLC v. Commissioner, the US Tax Court upheld a partnership’s distributions of "client-based intangible assets" (i.e., books…
Source: lexology.com
United States: Saved by the Bell… Almost
In US v. Weiss, the Third Circuit affirmed a district court’s grant of summary judgment to the government in a suit to collect an individual’s taxes…
Source: lexology.com
United States: IRS pushes filing requirements into uncertain territory
On 11 October 2022, the IRS published a draft Schedule Uncertain Tax Position ("Draft Schedule UTP") and corresponding Instructions. The IRS…
Source: lexology.com