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Blog

December 10, 2015 - 5:55 AM EST
How Congress Keeps Saving the Tax System From Treasury and the IRS
by Jeremy Scott
The conventional wisdom is that Congress passes messy laws and Treasury and the IRS have to use their regulatory authority to provide clarity and administrability. The recent changes to partnership audits are only the latest example of practitioners and observers crying out that provisions in legislation can't possibly work and that the government needs to save taxpayers and their advisers from a lawmaker-created muddle. But that conventional wisdom isn't always true. In fact, too often in the last few years, it's been Congress saving the fisc from bizarre administrative decisions from Treasury or the Service that have wounded the tax system.
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All blog posts by Jeremy Scott
December 9, 2015 - 8:59 AM EST
More Private Tax Collectors – A Monumentally Bad Idea
by David Brunori
On December 4 President Obama signed into law the Fixing America’s Surface Transportation Act. While it deals with funding transportation, the new law also contains a pernicious scheme to raise revenue. It requires the IRS to use private debt collectors.
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December 3, 2015 - 9:03 AM EST
What’s Next for Microsoft After Some Expensive Table Pounding?
by Stuart Gibson
Every experienced trial lawyer knows the saying, “When the facts are against you, pound on the law. When the law is against you, pound on the facts. When both are against you, pound on the table.”
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November 24, 2015 - 7:54 AM EST
Tax Credits Are Easy – And a Loser’s Game for Liberals
by Joseph J. Thorndike
Hilary Clinton’s presidential campaign is still churning out tax proposals at a furious pace. Over the weekend, she proposed a new credit for caretakers—intended, according to her campaign, to “provide support for the millions of families paying for, coordinating, or providing care for aging or disabled family members.”
[Read More]  (2 comments)

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October 30, 2015 - 8:48 AM EDT
Why Do We Still Have Unpublished Opinions?
by Cara Griffith
Newsflash…it’s 2015, and it might be time to reexamine the idea of unpublished opinions.
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All blog posts by Cara Griffith
September 21, 2015 - 9:21 AM EDT
Donald Buffett?
by Martin A. Sullivan
Two outspoken billionaires at opposite ends of the political spectrum reach the same conclusion.
[Read More]  (1 comment)

All blog posts by Martin A. Sullivan
September 15, 2015 - 3:46 PM EDT
Litigating FATCA: Rand Paul and Financial Privacy
by Robert Goulder
It’s not every day that a U.S. senator, let alone a presidential candidate, sues the government to suspend the enforcement of a federal tax law. Yet that is exactly what Sen. Rand Paul of Kentucky is doing. He is one of seven plaintiffs challenging the constitutionality of the Foreign Account Tax Compliance Act.
[Read More]  (7 comments)

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July 24, 2015 - 10:12 AM EDT
Donald Trump Is Contagious!
by Christopher Bergin
I’ve predicted that it will take two years to start a serious discussion of reforming the tax laws and the agency that administers them. After watching Rand Paul’s latest video, I’ve pushed that back a decade.
[Read More]  (9 comments)

All blog posts by Christopher Bergin
September 19, 2014 - 10:07 AM EDT
Renouncing the Dogma of Surrey’s Infallibility
by Ajay Gupta
Treasury’s export of Stanley Surrey’s arm’s-length standard was perhaps the most successful case of ideological conversion in the arena of international tax policy. Even as the United States inches away from that construct, the OECD clings to it with a zeal befitting a convert. Treasury may very well have to renounce the dogma of Surrey’s infallibility before true reform in the global transfer pricing regime can take place.
[Read More]

All blog posts by Ajay Gupta
July 11, 2014 - 9:39 AM EDT
International Tax Trending
by Mindy Herzfeld
This week’s international tax highlights include Jean-Claude Juncker’s agenda for EU tax policy, changes in the IRS’ international administration, and continued assertiveness by the U.S. and other governments in pursuing tax evasion while BEPS goes into sleep mode.
[Read More]  (1 comment)

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Today's News

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Federal Tax News from TaxAnalysts.com

FEDERAL HEADLINES
For Saturday, December 12, 2015

Economic Analysis: A Middle Path for Stopping Inversions

House Democrats Don't Support Permanent Extenders Deal, Pelosi Says

Non-Prosecution Agreements Will Not Protect Related Companies

House Approves Late Filing Penalty Bill; Obama Signs CR

Light Sentences Belie Seriousness of Tax Crimes, Official Says

Legislative Outlook: Lawmakers Seek Deals on Extenders, Spending

Subscribers to Expert3 or Tax Notes Today receive access to the full content for these articles plus many more on a daily basis. Our automated system can send you summary e-mails with links to the full content.
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State Tax News from TaxAnalysts.com

STATE HEADLINES
For Saturday, December 12, 2015

David W.T. Daniels and Margaret Winterkorn Meyers

Fee Structure Concerns Impeding MTC Transfer Pricing Program's Recruiting Efforts

U.S. House Passes Short-Term ITFA Extension and Separate Permanent ITFA Bill

Pennsylvania Court Holds Refund Limitation Period Begins on Date Tax Was Paid

Taxi Drivers Are Employees for UI Tax Purposes, Oregon Supreme Court Rules

Nevada Governor Seeks $215 Million in Incentives for Electric Car Plant

Subscribers to Expert3 or State Tax Today receive access to the full content for these articles plus many more on a daily basis. Our automated system can send you summary e-mails with links to the full content.
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International Tax News from TaxAnalysts.com

INTERNATIONAL HEADLINES
For Saturday, December 12, 2015

News Analysis: State Aid Cases -- EU Attacks the Lux Finance Branch

Luxembourg Open to Public CbC Reporting, Finance Minister Says

ATO Issues Warning on Split Procurement and Services Hub Structures

U.K. Bank Settles German Tax Probe of Swiss Unit

Brazil's Finance Ministry Calls for Tax Reforms to Avoid Another Debt Downgrade

Russia Issues Guidance on Nonresident Taxation

Subscribers to Expert3 or Worldwide Tax Daily receive access to the full content for these articles plus many more on a daily basis. Our automated system can send you summary e-mails with links to the full content.
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Featured News

December 11, 2015
The Unknowns of the Chan-Zuckerberg LLC
by David van den Berg
The announcement by Facebook co-founder and CEO Mark Zuckerberg and his wife, Priscilla Chan, that they will give nearly all of their Facebook stock to a new limited liability company they formed to work on social causes has generated enormous media attention, but also numerous questions, including on some tax-related aspects of the project.

December 8, 2015
Understanding the Accidental American: Tina's Story
by Allison Christians
Allison Christians is the H. Heward Stikeman Chair in Tax Law at McGill University in Montreal, where she writes and teaches in the area of national and international tax law and policy. You can follow her on the Tax, Society & Culture blog at taxpol.blogspot.com or on Twitter (@taxpolblog). She delivered the following speech at the International Conference on Taxpayer Rights in Washington on November 18.

December 7, 2015
Swiss Bank Program Non-Prosecution Agreements Accelerating
by Nathan J. Richman and Tom Kasprzak
Since the end of September, the number and size of non-prosecution agreements (NPAs) under the Justice Department's Swiss bank program have increased notably, the latest NPA announcement coming December 3.

November 30, 2015
IRS Pilot Attempts to Address Nettlesome ID Theft Issue
by Luca Gattoni-Celli
A pilot program contacting thousands of filers who might not have otherwise known that someone else used their Social Security number to gain employment will help the IRS better balance statutory mandates and filer interests, according to IRS Commissioner John Koskinen.

November 25, 2015
Lawmakers Eyeing $700 Billion Tax Extender Deal
by Stephen K. Cooper and Kaustuv Basu
House and Senate negotiators are working on a tax extenders package that would make the research credit permanent and delay the Affordable Care Act's "Cadillac" tax on high-cost healthcare plans for two years, according to a tentative outline obtained by Tax Analysts November 24.

November 19, 2015
Candidates Seek High Return From Repatriation Policies
by Paul C. Barton
To hear some presidential candidates tell it, if it were suddenly easy from a tax standpoint for U.S. corporations to repatriate more than $2.1 trillion in overseas earnings, the money would be in the next wire transfer home, giving the economy a jump-start like none before.

November 5, 2015
Tax Analysts Exclusive: Conversations: Nina Olson Stands Up for Taxpayer Rights
by William Hoffman
Olson recently spoke with Tax Analysts' William Hoffman about the differences between taxpayer rights and remedies, embedding taxpayer rights in the Internal Revenue Manual, and why Sweden's idea of taxpayer rights would never work in the United States.

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Video Channel

Watch Tax Analysts' video featuring a conversation with Lawrence B. Gibbs, former IRS Commissioner and a member of the law firm Miller & Chevalier, in which he discusses the current state of the IRS and its challenges.

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Watch Tax Analysts' video examining how some businesses are effectively audit proof. Read the supplementary article here.

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Watch the video of our conference on the taxpayer bill of rights.

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Watch a discussion on the net investment income tax with its drafters.

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