Join us at the 21st Annual International Tax Symposium

Sam Denton and TL Fahring will be speaking next month on International Tax Withholding at the 21st Annual International Tax Symposium, hosted by the State Bar of Texas Tax Section’s International Tax Committee. Join us November 8-9, 2018 at the Crowne Plaza Hotel in Houston. The State Bar has expanded this year’s Symposium to cover … Continue reading Join us at the 21st Annual International Tax Symposium

Facebook’s Face-Off with the IRS Over the Right to IRS Appeals

A recent U.S. District Court decision has preserved the IRS’s ability to act as gatekeeper to the IRS office of Appeals (“IRS Appeals”). However, there are signs that Congress may be moving to place restrictions on this gatekeeping ability. The decision in question involved a case brought by Facebook, Inc. (“Facebook”). The IRS had made … Continue reading Facebook’s Face-Off with the IRS Over the Right to IRS Appeals

Bad Debt Deduction Gone Bad (or The Worthwhileness of Proving Worthlessness)

Hatcher v. Commissioner, an unpublished per curiam opinion recently issued by the Fifth Circuit Court of Appeals, illustrates why taxpayers need to be sure that they can prove that a loan really became worthless in the year in which a bad debt deduction is claimed. In this case, the taxpayers (hereafter "Taxpayers") had married in … Continue reading Bad Debt Deduction Gone Bad (or The Worthwhileness of Proving Worthlessness)

New Tax Law May Encourage Aggressive Tax Positions

In a recent Urban Institution and Brookings Institution Tax Policy Center blogpost, Howard Gleckman noted that the Tax Cuts and Jobs Act may encourage taxpayers to take aggressive and potentially less than advisable tax positions. "[B]ecause the TCJA is both complicated and far-reaching, because it was rushed through Congress without careful review of its statutory … Continue reading New Tax Law May Encourage Aggressive Tax Positions

Green Solution Retail, Inc. v. United States – Supreme Court Denies Marijuana Cert

Two weeks ago, the U.S. Supreme Court denied a writ of certiorari requested by a marijuana dispensary that had sued to enjoin the IRS from investigating its business records. The case highlights how the federal income tax continues to pose difficulties for marijuana legalization. Green Solution Retail, Inc. sold marijuana out of several locations in … Continue reading Green Solution Retail, Inc. v. United States – Supreme Court Denies Marijuana Cert