As you may be aware, the Corporate Transparency Act (the “CTA”) is a new federal law that requires most U.S.-based companies, including corporations, partnerships and limited liability companies, to report information regarding their “beneficial owners” to the federal government through the
Larry's Tax Law
Larry's Tax Law, published by Foster Garvey PC, focuses on detailed analysis and commentary on federal tax law, with particular emphasis on Subchapter S corporations and their complex tax provisions. The blog covers legislative developments such as the One Big Beautiful Bill Act and its impact on business tax deductions, including bonus depreciation and automobile loan interest deductibility. It also provides insights into tax planning strategies, regulatory changes, and notable tax cases and rulings. The content is aimed at tax practitioners and professionals seeking to navigate nuanced tax regulations and optimize tax outcomes for clients.
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IRS Commissioner Werfel Issues the 2023-2031 Strategic Plan
On April 5, 2023, Commissioner Daniel I. Werfel issued the Internal Revenue Service Inflation Reduction Act Strategic Operating Plan (“Plan”). The Plan, which spans over 145 pages, is a roadmap to how the Service will deploy over the next decade…
When It Rains, It Pours in Washington State – The Washington Supreme Court Upholds the 2021 Enacted Capital Gains Tax
It is a rainy day in the Pacific Northwest with chances of snow showers. For those taxpayers that reside in the state of Washington or own highly appreciated capital assets located in the state, their day just got a bit…
Worker Classification in Light of Remote Workers May Need to be Revisited
INTRODUCTION
As I have discussed in prior blog posts (March 11, 2013, April 9, 2013 and December 9, 2013), worker classification has historically been a focus of attention of various government agencies as well as others. Misclassifying…
Taxpayers Take a Hit in the Washington Capital Gains Tax Battle
By motion dated November 3, 2022, the Washington State Attorney General asked the Supreme Court of the State of Washington to allow the Washington Department of Revenue to implement and collect the capital gains tax struck down as unconstitutional by…
A Narrow Aspect of the Check-the-Box Regulations that Deserves Some Press – Changing an Entity’s Tax Classification From That of a Partnership to That of an S Corporation
Introduction More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury Department are considering simplifying the classification regulations to allow taxpayers…
You’re Invited – NYU’s 81st Institute on Federal Taxation
The NYU 81st Institute on Federal Taxation (IFT) returns to in-person programming this year in New York City on October 23-28, 2022, and in San Diego on November 13-18, 2022. This year, I will be presenting my white paper “Entity…
Whether Public Law 86-272 is Alive and Well May Be Debatable – Santa Fe Natural Tobacco Co. v. Department of Revenue, State of Oregon
On August 23, 2022, the Regular Division of the Oregon Tax Court issued its opinion in Santa Fe Natural Tobacco Co. v. Department of Revenue, State of Oregon. The court determined that the taxpayer in that case is subject to…
The Remote Worker Platform Continues to Baffle the Tax and Human Resources Departments of Many Employers
As previously reported, due to the COVID-19 pandemic, remote workforces currently dominate the landscape of most U.S. businesses. In fact, in many industries, remote workforces may be the new normal post-pandemic. Unfortunately, as workers become more mobile, the tax…
The National Taxpayer Advocate Issued the IRS a Mid-Year Report Card
The Taxpayer Advocate Service (“TAS”) is an independent body housed within the Internal Revenue Service (the “Service” or “IRS”). Its mission is to ensure taxpayers are treated fairly by the Service and that taxpayers know and understand their rights with…