By Jonathan Prokup During a course that I taught about tax treaties at last week’s TEI Houston Tax School, one audience member asked whether the exchange-of-information provisions of U.S. tax treaties apply not only to the federal government but also to state and local governments. I had to confess that I did not know the [...]
Author Archive
Can Foreign Governments Obtain Taxpayer Information From State and Local Revenue Agencies?
February 28, 2012Who’s Afraid of the APA?: The Application Of Administrative Law To Tax Regulations
February 15, 2012By David Shakow The Supreme Court’s decision in Mayo Foundation for Medical Education and Research v. United States means that tax practitioners must be more sensitive to administrative law and judicial deference to administrative rules. This includes gaining some familiarity with the Administrative Procedure Act (APA) and the major cases that deal with judicial deference [...]
The Economic Substance Doctrine: Coming To A State Near You?
February 2, 2012By Jonathan Prokup Pennsylvania may soon join the other states that have challenged the use of the so-called Delaware Loophole, according to our colleagues at the State and Local Tax Blawg. The legislation, contained in Pa. House Bill 2150, would disallow deductions that a parent operating corporation claims for royalty payments made to a “Delaware [...]
Should Banks Be Entitled To Tax Deductions For “Dividends” On TARP Stock?
January 30, 2012By Jonathan Prokup & Dustin Covello Four years have passed since Congress enacted the Troubled Assets Relief Program, better known as TARP. After Treasury determined that frozen credit markets were threatening the U.S. financial industry and even the entire economy, it asked Congress to authorize the purchase of illiquid mortgages from banks. Congress obliged, authorizing [...]
Silence Is Golden: Can Treasury Offer Guidance About The Tax Consequences Of A Euro Breakup?
January 23, 2012By Jonathan Prokup In this morning’s Tax Notes (subscription required), Jeremiah Coder addresses a topic that we at the Tax Blawg have discussed a couple of times over the past two years: the tax consequences of a potential breakup of the euro. For our prior coverage, see here and here. As the currency lurches towards [...]
Treasury Finalizes Conduit Financing Regulations Under Section 881
January 9, 2012By Jonathan Prokup On December 9th, the IRS issued final regulations under Code section 881 that treat a disregarded entity as a person to determine whether a “financing arrangement” exists for purposes of applying the conduit financing regulations. The finalized regulations may deny tax benefits otherwise available from U.S. tax treaties when a multi-party financing [...]
The IRS Can Summons California For Property Transfer Records
December 20, 2011As noted by Janet Novack at forbes.com, Judge England of the District Court for the Eastern District of California last week issued an order permitting the IRS to serve a “John Doe” summons on the California State Board of Equalization. The summons seeks the names of residents who transferred property to relatives for little or [...]
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
dustincovello
