The Economic Substance Doctrine: Coming To A State Near You?

By 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 … Continue reading The Economic Substance Doctrine: Coming To A State Near You?

Innocent Spouse Relief After Mayo: Congress Strikes Back?

By David Shakow Following the Supreme Court’s decision in Mayo Foundation v. United States, in which the Court ruled that tax regulations receive deference from courts under the Chevron doctrine that applies to non-tax regulations, many commentators acknowledged the decision’s anticipated impact on disputes about the validity of tax regulations.  The new standard gives the … Continue reading Innocent Spouse Relief After Mayo: Congress Strikes Back?

Tax Talk Around The Web

By Jonathan Prokup Business Spectator: Stalled R&D legislation stunts innovation (Australia).  As we discussed previously, temporary legislation makes for lousy tax policy, a problem that Australia seems to be experiencing right now. Forbes - Business in the Beltway: Taxes? Hold ‘Em!.  It seems that the pending deal on individual taxes will include a one-year extension … Continue reading Tax Talk Around The Web

The Moment of Truth: Is Tax Reform Coming?

By Jonathan Prokup Recalling one of our first blawg posts, the topic of tax reform could be described in much the same terms as the codification of economic substance (prior to its codification, anyway): "a cousin of Bigfoot and the Loch Ness Monster – often spotted, but never confirmed."  Reform commissions come and go with … Continue reading The Moment of Truth: Is Tax Reform Coming?