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States Use Jeopardy Assessments as Effective Collection Mechanism

There are situations in which state tax authorities determine that ordinary assessment and collection efforts will be ineffective. Although most practitioners do not experience application of the jeopardy assessment provisions often, it is important to maintain an awareness of the provisions, since the...

State Tax Practice Focused on Foreign Source Income; Criminal & Civil Enforcement

The expanding global economy has increased state taxation of business enterprises that conduct operations on an international level. These business taxpayers are subject to taxation in multiple jurisdictions with diverse laws that have few shared relevant substantive provisions. The U.S. Constitution...

In Extraordinary Circumstances, States Use Jeopardy Assessments as Effective Collection Mechanism

While most states have extensive statutory and regulatory authority providing for ordinary assessment and collection procedures, there are certain situations in which the state authorities determine that those assessment and collection efforts will be ineffective. These situations may include circumstances...

In Extraordinary Circumstances, States Use Jeopardy Assessments as Effective Collection Mechanism

While most states have extensive statutory and regulatory authority providing for ordinary assessment and collection procedures, there are certain situations in which the state authorities determine that those assessment and collection efforts will be ineffective. These situations may include circumstances...

State Tax Practice Focused on Foreign Source Income; Criminal & Civil Enforcement

The expanding global economy has increased state taxation of business enterprises that conduct operations on an international level. These business taxpayers are subject to taxation in multiple jurisdictions with diverse laws that have few shared relevant substantive provisions. The U.S. Constitution...