For the May federal tax advisory, we considers the unclear tax powers of the bankruptcy courts and how the IRS won’t take any determinations too kindly. Prepetition tax claimsThe IRS’s constitutional and statutory defensesBankruptcy … [Continue reading] about Tax Determinations in Bankruptcy
Risky Business – Allocating Losses When Your Supply Chain Is Disrupted
Should a subsidiary incur losses due to risks it assumed? Can a parent take on losses? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions multinational enterprises can take now … [Continue reading] about Risky Business – Allocating Losses When Your Supply Chain Is Disrupted
IRS Issues COVID-19 Forbearance Guidance for REMICs and Investment Trusts
Yesterday, our Federal Tax Group discussed a new Revenue Procedure from the IRS that provides useful real estate mortgage investment conduit (REMIC) and investment trust safe harbors for mortgage loan payment forbearances (and related … [Continue reading] about IRS Issues COVID-19 Forbearance Guidance for REMICs and Investment Trusts
NY Tribunal Disallows Broker-Dealer Sourcing for Receipts from a Disregarded LLC
Our State & Local Tax Team discusses a decision from the New York Tax Appeals Tribunal that holds that a single member of a broker-dealer is not entitled to use broker-dealer sourcing in NY. Decision impacts millions at stake for NY … [Continue reading] about NY Tribunal Disallows Broker-Dealer Sourcing for Receipts from a Disregarded LLC
What’s Your Source? Proposed Regulations on Sourcing Inventory Sales
Is your inventory sales income U.S. or foreign source? Well, it depends. In case you missed it, our International Tax Group explores the various sourcing rules the IRS has proposed to sort out possible inconsistencies and overlaps caused by the Tax … [Continue reading] about What’s Your Source? Proposed Regulations on Sourcing Inventory Sales